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Providing Telehealth Services Under Medicare During the COVID-19 Pandemic

Updated on May 7, 2020

In response to the spread of COVID-19, the Centers for Medicare & Medicaid Services (CMS) now allows audiologists and speech-language pathologists (SLPs) to provide telehealth services to Medicare Part B (outpatient) beneficiaries, retroactive to March 1, 2020, and for the duration of the public health emergency. CMS announced this expansion in an April 30, 2020, press release and its COVID-19 Emergency Declaration Blanket Waivers for Health Care Providers [PDF]. ASHA and its members participated in extensive advocacy with Medicare to achieve this expansion.

Medicare Part C (Medicare Advantage plans) may also reimburse for telehealth services provided by audiologists and SLPs during the public health emergency. Check with the plan directly for coding and billing guidelines.

Note: ASHA uses the term telepractice . Any reference to telepractice includes telehealth, which is Medicare’s term for the health care services delivered via interactive audio and video telecommunications technology with real-time capability.

On this page: 

What to Know Before You Get Started

Clinical, Ethical, and Legal Considerations

ASHA guidelines state that the use of telehealth must be equivalent to the quality of in-person services and must adhere to the ASHA Code of Ethics, audiology or speech-language pathology scope of practice, state and federal laws, and ASHA policy.

Clinicians must also consider their own skill/experience and the patient’s needs and capabilities before beginning telehealth services. To ensure compliance, you should do the following: 

Private Pay Arrangements

Medicare’s temporary expansion of telehealth services means that audiologists and SLPs may no longer enter into a private pay arrangement with Medicare beneficiaries for those services that are now included on Medicare’s telehealth list. For codes that are not authorized telehealth services, audiologists and SLPs can continue to accept private payment from Medicare beneficiaries.

Enrolled Medicare Providers

If you delivered covered telehealth services to a Medicare beneficiary under a private pay arrangement at any time since March 1, 2020, you should return those funds and submit the claim(s) to Medicare.

Not Enrolled in Medicare

If you delivered covered telehealth services to a Medicare beneficiary under a private pay arrangement at any time since March 1, 2020, you should return those funds. Unenrolled providers may not submit claims to Medicare for reimbursement and may not enter into private pay agreements with Medicare beneficiaries for covered services.

If you want to deliver covered telehealth services to Medicare beneficiaries during the public health emergency or beyond, you must enroll as a Medicare provider. Federal law requires mandatory enrollment and claims submission for Medicare covered services.

CMS currently allows certain flexibilities to expedite temporary provider enrollment [PDF] into the Medicare program during the public health emergency.

Equipment and Security Requirements

CMS has waived certain equipment and HIPAA requirements during the public health emergency. Clinicians can now use nonpublic facing platforms that allow two-way, real-time interactive communication but aren’t HIPAA-compliant. Examples of acceptable platforms listed by CMS include Apple FaceTime, Facebook Messenger video chat, Google Hangouts video, Zoom, or Skype.

Examples of public facing platforms that aren’t acceptable include Facebook Live, TikTok, or Twitch. Telephones with no video function are temporarily approved for a limited set of telehealth services, and may also be used for other communication technology-based services.

Approved Patients and Locations

Although Medicare only allows established patients to receive telehealth services, CMS has said it will not conduct audits to ensure that a prior relationship existed during the public health emergency. This means that clinicians may provide telehealth services to both new and established patients. Clinicians should consider state practice acts or other local laws and regulations before beginning services with new patients. Clinicians may be required to evaluate new patients before providing clinical recommendations or treatment.

CMS also removed limitations on where Medicare patients must be located to be eligible for telehealth services. Patients outside of rural areas and patients in their homes can now receive telehealth services. Clinicians may also provide services from their own home.

Patient Consent

During the public health emergency, the patient must consent to receive services via telehealth at least once annually. You or your administrative staff can obtain verbal consent and notify the patient of applicable co-pay and deductible costs at the same time you provide the service. Be sure to document that you received the verbal or written consent.

Institutional Billing

Skilled Nursing Facilities (SNFs) and Home Health Agencies

SNFs and home health agencies currently do not appear to be able to bill for telehealth services. ASHA will continue advocating for additional waivers, as necessary. In its home health fact sheet [PDF], CMS states that only in-person services can be reported via the home health claim even when the plan of care is developed or updated to include the use of telecommunication technology. In a similar fact sheet for SNFs [PDF], CMS notes that only in-person visits by physician and nonphysician practitioners are eligible for delivery via telehealth. Audiologists and SLPs are suppliers under Medicare’s definition and are not eligible to bill for practitioner services. However, Medicare officials have stated that services provided via audiovisual equipment—such as a smartphone or platforms like FaceTime or Skype—in the same building as the patient or through the patient’s window are allowed but are considered in-person services and not telehealth services.

Hospital Outpatient Departments (HOPDs)

(added 5/7/20)

According to the CMS press release and related guidance for HOPDs [PDF], “hospitals may bill for services furnished remotely by hospital-based practitioners to Medicare patients registered as hospital outpatients, including when the patient is at home...” when the hospital has registered the patient’s home as a temporary expansion location with the CMS Regional Office. Audiologists and SLPs should work with their hospital to ensure each patient’s home is registered with the regional office and that services are provided remotely only when clinically appropriate for the patient.

According to CMS, if the patient is a registered outpatient of the hospital and is in a temporary expansion location of the outpatient department (including the patient’s home), the service can be provided via audiovisual equipment. In cases where both audio and visual are not available, the service can be furnished exclusively with audio. These services can be provided by the hospital’s clinical staff and should be billed as if they were provided in the hospital.

These services are not considered Medicare telehealth services but are considered services provided in person to the patient. While the list of CPT codes included with the guidance [ZIP] is illustrative and not exhaustive, ASHA is requesting codes reflective of audiology and speech-language pathology services be added to the list.

Covered Audiology and Speech-Language Pathology Services

Medicare’s telehealth services list outlines approved services by Current Procedural Terminology (CPT) code. Clinicians should not use CPT codes on the approved list to submit claims for other telehealth services not included on this list. For example, do not use CPT code 92523 (speech and language evaluation) to bill for a standardized cognitive assessment, which is reported with CPT code 96125 and is not on the telehealth list. ASHA will continue to work with Medicare to add more audiology and speech-language pathology services to the covered telehealth list. 

Clinicians must follow Medicare requirements for covered services, whether provided in person or via telehealth. For example, audiology services require a physician referral, and speech-language pathology services should include physician certification of the plan of care. Chapter 15 of the Medicare Benefit Policy Manual [PDF] outlines coverage and documentation requirements for Medicare Part B services.

Codes not included on this list may be provided via telehealth to Medicare beneficiaries under a private pay arrangement, with the patient's consent.

Audiology CPT Codes

The following codes represent audiology services covered under the Medicare telehealth benefit.

  • 92601: Diagnostic analysis of cochlear implant, patient younger than 7 years of age; with programming
  • 92602: Diagnostic analysis of cochlear implant, patient younger than 7 years of age; with programming; subsequent programming
  • 92603: Diagnostic analysis of cochlear implant, age 7 years or older; with programming
  • 92604: Diagnostic analysis of cochlear implant, age 7 years or older; with programming; subsequent programming

Speech-Language Pathology CPT Codes

The following codes represent speech-language pathology services covered under the Medicare telehealth benefit.

  • 92507: Treatment of speech, language, voice, communication, and/or auditory processing disorder; individual
  • 92508: Treatment of speech, language, voice, communication, and/or auditory processing disorder; group
  • 92521: Evaluation of speech fluency (eg, stuttering, cluttering)
  • 92522: Evaluation of speech sound production (eg, articulation, phonological process, apraxia, dysarthria);
  • 92523: Evaluation of speech sound production (eg, articulation, phonological process, apraxia, dysarthria); with evaluation of language comprehension and expression (eg, receptive and expressive language)
  • 92524: Behavioral and qualitative analysis of voice and resonance

CMS also allows these speech-language pathology services to be conducted via telephone-only in those cases where the patient does not have access to audiovisual equipment. These services may still be reported to Medicare as telehealth services using the appropriate CPT codes and telehealth modifier during the public health emergency.

Coding and Billing Guidelines

Audiologists and SLPs providing telehealth services should report the same CPT codes and follow the same coding guidelines as they would for in-person services, including same-day billing rules and time requirements. For example, a brief check-in via telecommunication technology should not be reported with an evaluation or treatment CPT code (such as 92507 or 92601) and is not considered a Medicare telehealth service.

Medicare telehealth services are reimbursed at the same rate as in-person services paid under the Medicare Physician Fee Schedule for Part B services.

Place of Service (POS) and Modifiers

Medicare now allows Part B providers who perform telehealth services to report the POS code that reflects the location where in-person services would have been provided. Providers should also append the modifier -95 (synchronous telemedicine service) to each CPT code provided via telehealth. Modifier -95 indicates telehealth services provided in an outpatient nonfacility setting. Providers in outpatient settings should not use POS 02 (telehealth) because this will result in payment at the facility rate.

For example, a clinician who provides telehealth services from their own home, but would normally have seen their patients in their private practice, would use POS 11 (office) and include modifier -95 for each CPT code reported.

SLPs should also append the -GN modifier to all CPT codes to indicate services provided under a speech-language pathology plan of care.

Communication Technology-Based Services Versus Telehealth Services

Communication technology-based services (CTBS) are not considered telehealth services under Medicare’s definition. According to Medicare, telehealth services represent services that would normally occur in person. On the other hand, CTBS codes represent brief communication services conducted over different types of technology to help avoid unnecessary office visits and slow the spread of COVID-19. They do not replace full evaluation and treatment services covered under the Medicare benefit and described by existing CPT codes for telehealth/in-person services. CTBS codes are limited in scope and reflect brief, patient-initiated check-ins or consultations that require clinical decision-making.

Medicare allows SLPs to report CTBS codes during the public health emergency.

Providing Noncovered Audiology and Speech-Language Pathology Services

Medicare’s temporary coverage of telehealth services means that audiologists and SLPs may no longer enter into a private pay arrangement with Medicare beneficiaries for those services that are now included on Medicare’s telehealth list. Clinicians may continue to accept private payments from Medicare beneficiaries for services not included on the telehealth list. However, if Medicare adds more services to the approved telehealth list, enrolled Medicare providers must reimburse their patients for those services and submit claims to Medicare for payment. Unenrolled providers must also reimburse their patients, but may not submit claims to Medicare for reimbursement and may not enter into private pay agreements with Medicare beneficiaries for covered services.

Informed Consent

Because telehealth services not included on the telehealth list are statutorily excluded from Medicare coverage, clinicians aren’t required to provide an Advance Beneficiary Notice (ABN) [PDF] of financial liability to the Medicare beneficiary. However, an ABN may be given as part of the informed consent necessary for engaging any patient in a private contact to make direct payment for non-covered telehealth services. ASHA also recommends that clinicians clearly inform the Medicare beneficiary, in writing, that Medicare covers audiology and speech-language pathology services provided in-person and have them voluntarily confirm their desire to receive services via telehealth.

Establishing Rates

The Medicare fee schedule does not directly apply to services statutorily excluded from Medicare coverage. ASHA recommends following the Medicare Physician Fee Schedule (MPFS) rates for private pay contracts with Medicare beneficiaries for telehealth services. Medicare reimburses providers at the same rate for both in-person and telehealth services, when covered. ASHA recommends following that precedent. Some adjustments to MPFS rates can be made to accommodate the financial needs of the patient under a written policy that applies to all patients, regardless of form of insurance.

Legal and Regulatory Foundation

Although CMS has temporarily waived certain telehealth laws, allowing audiologists and SLPs to provide some telehealth services during the public health emergency, Section 1834(m) of the Social Security Act (SSA) precisely defines telehealth as a service provided by a physician or practitioner under the Medicare benefit. The SSA currently classifies audiologists and SLPs as suppliers. This means standing Medicare law doesn’t recognize audiologists and SLPs for reimbursement for telehealth services. This statutory exclusion eliminates such services from Medicare service delivery requirements and shifts financial liability for paying for the services to beneficiaries at the discretion of the patient. As a result, audiologists and SLPs may provide non-covered telehealth services to Medicare beneficiaries and enter into private pay contracts to receive reimbursement, if the patient agrees. This interpretation is supported by a series of direct communications with CMS staff, engagement with external experts familiar with Medicare law, and in consultation with other professional associations.

Section 50.3.2 of Chapter 30 of the Medicare Claims Processing Manual [PDF] also makes it clear that when services are statutorily excluded from coverage, Medicare policy does not apply, there is no Medicare reimbursement, and the use of an ABN is voluntary.

It is important to note that the statutory exclusion of certain telehealth services creates this unique exemption from coverage. Audiologist and SLPs cannot opt out of Medicare and must comply with all regulatory requirements when they provide covered services to Medicare beneficiaries, including temporarily covered telehealth services. 

Resources

Contact reimbursement@asha.org for additional information. Check this webpage and ASHA’s COVID-19 Updates page frequently for the latest developments related to Medicare, Medicaid, and commercial insurance coverage of telehealth services during the COVID-19 pandemic.

CMS also publishes extensive resources, including frequently asked questions [PDF], to help providers during the public health emergency.

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