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Payment and Coverage of Telepractice Services

Considerations for Audiologists and Speech-Language Pathologists

Please see ASHA's resource on payment and coverage of telepractice during the COVID-19 pandemic. However, clinicians should also be aware of the following payment and coverage considerations absent emergency guidelines related to audiology or speech-language pathology telepractice services.

Telepractice is considered an appropriate model of service delivery for audiologists and SLPs, 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.

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State Laws and Regulations

Many states have licensure requirements and policies regarding telepractice that audiologists and SLPs 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). See ASHA's state-by-state pages for information on state-specific telepractice laws and regulations. Although these laws may allow audiologists and SLPs to provide telepractice services, clinicians should also consider payer policy before proceeding. Payers may not yet have implemented guidelines for the provisions of telepractice services and may not reimburse for them. Before you begin providing services via telepractice, always verify with each payer that they will reimburse for audiology or speech-language pathology telepractice services and confirm payer guidelines for reimbursement, billing, coding, modifier use, student/clinical fellow supervision, and coverage. 

Payer Policies

Audiologists and SLPs 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

Note: Medicare will temporarily cover telepractice services by audiologists and SLPs during the COVID-19 pandemic, retroactive to March 21, 2020, and for the duration of the public health emergency. Please review ASHA’s COVID-19 information before beginning telepractice services with Medicare beneficiaries at this time.

Under current Medicare law, audiologists and SLPs are not statutorily authorized Medicare providers of telepractice and clinical audiology and speech-language pathology services aren’t on the list of Medicare telepractice services payable under the Medicare Physician Fee Schedule. As a result, evaluation and treatment provided by audiologists and SLPs via telepractice aren’t Medicare covered services and are exempt from Medicare requirements. Audiologists and SLPs may enter into a private pay contract with Medicare beneficiaries to furnish the telepractice services at the request of the patient. Learn more about the exemption before entering into a private pay agreement with a Medicare beneficiary for services provided via telepractice.

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 SLPs 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 and/or place of service codes 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 and/or place of service codes should be used to indicate services were delivered via telepractice

Coding and Billing

CPT Codes

Coding for evaluation and treatment services is typically accomplished using the same CPT codes, regardless of mode of delivery. As such, audiologists and SLPs providing telepractice services should report CPT codes just as you would if the services were provided face-to-face and follow the same guidelines for appropriate billing. For example, a brief check-in via a telepractice platform should not be reported with an evaluation or treatment CPT code (such as 92507 or 92626). See ASHA's coding and payment web pages for a full list of audiology and speech-language pathology related CPT codes. Payers may also have a specific list of CPT codes approved for telepractice services. Always verify with the payer before initiating services.

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. To append a modifier, place it in the the "modifier" section of the claim, on the same line as the CPT code. Audiologists and SLPs should check with each payer to verify appropriate use of modifiers to reflect telepractice services. Payers may also opt to use a place of service (POS) code to indicate services conducted via a telepractice system.

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 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 use of telepractice-related modifiers on the claim form.

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  Telehealth (The location where health services and health-related services are provided or received through a telecommunication system) 

If a payer does not recognize POS 02 for telepractice, clinicians should report the POS that best reflects the location of the rendering provider, not the location of the patient. For example, if you provide services from your private practice or home office, consider using POS 11 for "office". POS 11 describes a setting other than a hospital or other facility where a health care professional routinely provides evaluation and treatment services.

Resources

ASHA Corporate Partners