CMS Confirms Flexibility to Use Audiovisual Technology to Deliver In-Person Services When in the Same Building

April 9, 2020

Centers for Medicare & Medicaid Services (CMS) staff has stated that therapists, including speech-language pathologists (SLPs), may provide evaluation and treatment services to patients in skilled nursing facilities (SNFs) via audiovisual devices, and that these services, for billing purposes, would be considered in-person services when provided in the same building as the patient.

Smartphones or tablets can be used to provide evaluation and treatment, when clinically appropriate, and should be reported as in-person services, not telehealth, said Emily Yoder, an analyst with CMS’s Division of Practitioner Services, during an open-door forum held by CMS on April 8. Yoder reiterated these statements to Skilled Nursing News, a SNF trade publication. 

“As long as both patient and provider are in the same building, therapists can bill for services conducted over audiovisual devices as though they were performed face-to-face,” Yoder said.

This new flexibility is not considered an expansion of telehealth coverage or eligibility by CMS. However, this flexibility does provide SNFs and SLPs an important opportunity to continue providing medically necessary, skilled services to those patients who require them, while reducing the risk of disease transmission during the COVID-19 pandemic. ASHA encourages SLPs in SNFs to use this virtual model of service delivery when deemed clinically appropriate, and not exclusively for the convenience of the SNF or the clinician. In addition to the considerations for patient selection listed in the ASHA practice portal page on telepractice, some other factors to consider are patients’ diagnoses and severity, overall clinical presentation and related precautions to reduce risk of disease transmission during the COVID-19 pandemic, and availability of appropriate personal protective equipment for providers. More information can be found in ASHA’s practice portal page on telepractice and in ASHA’s telepractice resources during COVID-19.


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