Reimbursement of Telepractice Services

Considerations for Audiologists and Speech-Language Pathologists

Telepractice is considered an appropriate model of service delivery for audiologists and speech-language pathologists, when clinically appropriate. However, clinicians must ensure that telepractice services are delivered within the confines of clinical and practice guidelines, state and federal laws and regulations, and payer policies. The following information focuses on policies related to reimbursement for telepractice services.

State Laws and Regulations

Many states have licensure requirements and policies regarding telepractice that audiologists and speech-language pathologists should be aware of. Many have also passed laws and regulations requiring state Medicaid agencies or private health plans to reimburse for services delivered via telepractice, if those same services are reimbursable when provided face-to-face (i.e., in person). Although these laws may allow audiologists and speech-language pathologists to provide telepractice services, payer policy must also be considered before proceeding. Payers may not yet have implemented guidelines for the provisions of telepractice services and may not reimburse for them. Before they begin providing services via telepractice, audiologists and speech-language pathologists should always confirm with each payer that telepractice services will be reimbursed and confirm payer guidelines for reimbursement, billing, coding, modifier use, student/clinical fellow supervision, and coverage. 

Payer Policies

Audiologists and speech-language pathologists should keep in mind that although a state may have passed telepractice reimbursement laws, this does not guarantee that payers will reimburse for these services. Always verify payer coverage policies before beginning to provide telepractice services.

Medicare

Under current Medicare legislation, audiologists and speech-language pathologists are not considered eligible providers of services delivered via telepractice because Medicare restricts the delivery of services via telepractice to specific provider types. This means that audiologists and speech-language pathologists cannot provide their services via telepractice to Medicare beneficiaries. Some providers may believe that because they are not eligible providers of services delivered via telepractice, they can enter into private-pay agreements with beneficiaries or provide an Advance Beneficiary Notice (ABN) to the beneficiary, since Medicare would not reimburse for those services. However, because audiology and speech-language pathology services are covered services under the Medicare benefit, the services must be provided to Medicare beneficiaries within the confines of Medicare rules.

Medicaid

CMS encourages state Medicaid agencies to develop approaches to telepractice and coverage expansion, but each state’s Medicaid agency can make their own guidelines for telepractice reimbursement. Although some states have passed laws requiring the Medicaid agency to reimburse for services delivered via telepractice, audiologists and speech-language pathologists should contact the Medicaid agency for guidance on the following:

  • Which services may or may not be covered when delivered via telepractice
  • What provider types are eligible to deliver services via telepractice
  • Which Current Procedural Terminology (CPT ®) codes are eligible for telepractice
  • Which modifiers should be used to indicate that services were delivered via telepractice

Private Insurance

Each private insurance plan can decide whether they will reimburse for telepractice services. Like Medicaid, although some states may have passed laws requiring private insurance plans to cover telepractice services, audiologists and speech-language pathologists should contact the plan for guidance on the following:

  • Which services may or may not be covered when delivered via telepractice
  • What provider types are eligible to deliver services via telepractice
  • Which CPT codes are eligible for telepractice
  • Which modifiers should be used to indicate services were delivered via telepractice

Coding

Coding for evaluation and treatment services is typically accomplished using the same CPT codes, regardless of mode of delivery. As such, audiologists and speech-language pathologists providing telepractice services should report CPT codes just as they would report them if the services were provided face-to-face. Modifiers are often reported in conjunction with the CPT codes to reflect that services were provided via telepractice. 

Modifiers

Modifiers related to telepractice—available through both the CPT coding system and the Health Care Common Procedure Coding System (HCPCS)—are appended to CPT codes to indicate mode of service delivery. Audiologists and speech-language pathologists should check with each payer to verify appropriate use of modifiers to reflect telepractice services.

HCPCS

GQ Telehealth service rendered via asynchronous telecommunications system

GT  Telehealth service rendered via interactive audio and video telecommunications system

CPT

95  Synchronous telemedicine service rendered via a real-time interactive audio and video telecommunications system

Note: Modifier 95 was created through the CPT system for 2017 and can be appended to CPT codes to reflect services that were provided via real-time telecommunication systems. This code does not replace the existing GQ and GT modifiers that were created through the HCPCS by the Centers for Medicare & Medicaid Services (CMS). Clinicians should check with individual payers regarding implementation and use of telepractice-related modifiers on the claim form for 2017.

Place of Service Codes

Place of service codes are used on claims to indicate the specific type of location where services were provided. Clinicians should verify with individual payers regarding implementation and use of the POS code for telepractice, listed below. More information on POS codes is available on the CMS website.

02  The location where health services and health-related services are provided or received through a telecommunication system.

Resources

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