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There’s a whole lotta talk about why you should use telehealth in your physical therapy practice right now (e.g., scheduling flexibility, financial stability, and reduced no-shows). But what about how to use it? After all, any new technique or technology is bound to come with a learning curve—and if you’re implementing it in your practice on a tight schedule, you need that curve to be a short one. To that end, we’ve created this resource that PTs can use to guide themselves through a typical telehealth visit. Here’s what you need to know:

Knock out your logistical to-dos.

First, make sure you have everything you need before sitting down in front of your computer or mobile device. Specifically, be sure you’ve:

  • collected the patient’s intake information prior to the appointment;
  • acquired a signed patient consent form;
  • reached out to your patient on the day of the appointment to remind him or her about the service and go over expectations, technology requirements, and best practices; and
  • notified the patient when the appointment has started.

Ensure you have the proper setup.

Prior to conducting a telehealth visit, be sure your treatment area is set up and ready to go. You’ll want to make sure you’re working in a well-lit room that’s far away from any noise and has minimal distractions. In fact, you may want to come up with a system to ensure your team knows when you’re on a telehealth call and thus, cannot be interrupted.

Next, double-check your audio device and camera to make sure everything’s working as intended. You don’t want to start your telehealth session only to keep the patient waiting while you troubleshoot technical difficulties. However, technology snafus can—and do—happen, so be sure you have a phone handy to dial-in if necessary. If you’re conducting virtual visits from your home, take all of the necessary precautions to protect your patient’s privacy by conducting the visit in a room that’s out of view of spouses, children, or roommates.

Launch your video application.

Assuming you notified your patient ahead of time, he or she should already be waiting for you in the virtual session. If your telehealth platform has a waiting room function, admit the patient into the session and greet him or her upon arrival.

Get the patient set up for the session.

Before you get down to business—er, treatment—there are a few preliminary items to get out of the way first. If this is your first telehealth session with the patient, ask him or her whether he or she has:

  • had a telehealth visit before, and
  • used this particular telehealth platform.

Then, show the patient around and point out any tools he or she may need to use throughout the visit. Additionally:

  • Confirm that the patient can see and hear you well enough—and that there are no connectivity issues.
  • Ensure the patient is comfortable, and give him or her an opportunity to ask any questions before getting started.
  • Make sure the patient has adequate space to perform all the movements.
  • Ask the patient to verify his or her:
    • full name,
    • date of birth, and
    • current geographic location.

You may also want to confirm the type of device the patient is using, as this may influence the type of treatment you provide. For example, if you’re planning to assess general mobility of a joint or a common orthopedic condition, then a laptop is the preferred device. It’s easier to position a laptop’s camera to get a full field of view when necessary, and it’s generally a less-clunky experience. Mobile devices are also an option—and can be particularly helpful for getting close-up shots of specific areas—but they require a little more creativity when it comes to positioning the camera.

Load the SOAP note.

Now, you’ll start your visit just as you would in the clinic: by opening up your documentation software and loading a SOAP note. (You’ll want to make sure you can still see the patient while you have your note open—something your telehealth platform should allow you to do.)


In terms of documenting the assessment, some aspects will be similar to what you’re used to for in-person visits, while others will be a bit different. For the subjective portion, the only real difference between completing this portion during a telehealth visit versus an in-person visit is that you’re connecting over a video screen.


Things get a little tricker with the objective portion. This will require some practice to perfect, and it’ll definitely challenge your creativity and problem-solving skills. This portion will differ from patient to patient depending on the condition being treated. However, functional assessments are incredibly helpful.

Help your patient with camera placement so you can get the full field of view. Then, watch movement patterns and estimate limitations in range of motion or strength based on functional deficits with common activities. Verbal cueing during assessments is more important than ever. Also, don’t forget about your patient-reported outcomes. These measurement tools are your friends during remote treatment sessions—even more so than during in-person visits.


While the assessment portion of a telehealth visit will be pretty similar to that of an in-person visit, one additional attribute of your assessment will be deciding whether this patient is appropriate for telehealth. If you feel as though you’re not equipped to properly manage this patient’s condition via telehealth, you should discontinue virtual treatment. For example, if the patient requires manual interventions or cannot safely receive telehealth treatment, he or she would not be a good candidate for telehealth. However, this is ideally something you’ve already taken into consideration before scheduling the visit.


In the plan section, your creativity and problem-solving skills will again be critical to your success. You’ve likely treated patients who’ve shifted to self-management of their condition for a period of time—whether that’s due to them going on vacation mid-treatment or transitioning to self-managed care—and you’re equipped to give patients the tools they need to be successful outside of your treatment sessions.

Home Exercise Program

Home exercise programs are always a crucial component of rehab therapy treatment—whether or not that treatment occurs virtually. For telehealth patients, though, one great trick is to use your telehealth platform’s screen-sharing tool to review the HEP during a live treatment session. That way, you can show patients exactly what you see on your screen—which is exactly what they’ll see when you send the HEP to them after the appointment. Walk the patient through all of the exercises to make sure he or she is crystal clear on how to properly complete them. Of course, when you share your screen, make sure you don’t have any other patient charts or PHI pulled up.

Follow up with the patient.

Your entire telehealth visit is important, but it’s absolutely crucial that you stick the landing. After all, there’s no warm transfer to a friendly face at the front desk to check the patient out or schedule future appointments. Using a secure patient portal or online HEP, send the patient his or her at-home exercises, along with a satisfaction survey. (We suggest using the Net Promoter Score® survey, but any satisfaction survey will do.) You should also notify the front office staff so they can reach out to the patient immediately to schedule his or her next appointment while it’s top of mind.

So, there you have it: a step-by-step guide to conducting a physical therapy visit via telehealth. To see an example of this process in action, check out this demo with WebPT’s Director of Product Management, Scott Hebert, DPT:


And, as always, feel free to leave any questions you have in the comment section below!

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There is no question that the current global situation is going to leave a mark. Regardless of how you feel about the pandemic—and the regulations being implemented to address it—the past three months have changed us. To what end? It’s not yet clear, but the one thing I do know is that we have a choice in how we approach this new phase—as individuals, as practice owners, and as a professional community. Sure, I have my thoughts on how we can set ourselves up for success in the months and years to come—business acumen and access to capital are two things that come to mind—but I also have more than a few unanswered questions about the shape our industry will take on the other side of this.

That’s why I thought I’d use my monthly letter to this community to open the floor for discussion on some of the things I’ve been reflecting on. I’d love to hear your thoughts on these topics—as well as any others that you’d like to add to the mix—in the comment section at the end of this article. While we might not be able to solve any of the challenges discussed today, open dialogue can help generate momentum, and that’s exactly what we need right now.

Things are trending up—but is it enough?

I’m a big proponent of data. Anecdotes and stories have their rightful place, but data is so, so important—which is why my team has been actively analyzing data from our more than 80,000 Members to shed light on trends around new initial evaluations, patient visits, and appointment cancellations. What we found won’t surprise anyone: almost all rehab therapists experienced a massive patient drop-off in mid-March, but in the last several weeks, things have begun to trend up again. This implies that the industry is rebounding, but at what rate and to where?

As of mid-May, 29 states were in the process of relaxing restrictions on elective surgeries, and we expect this will translate into more physical therapy referrals and more overall visits. In fact, in a recent webinar, Definitive Healthcare shared data illuminating a significant pent-up demand for elective surgeries in some of the country’s largest metro areas, including New York City, Phoenix, Los Angeles, Dallas, and Atlanta.

Additionally, cancellation rates hit a new low since this crisis began (17.8%), and the ratio of initial evaluations to total visits is now holding steady at around 10%, signaling that new patient volume is on the rise. As of late May, the national average for daily patients seen per therapist was 6.6. For reference, this number was 8.8 in January, prior to the pandemic.

That said, at one point, 30% of our Members weren’t seeing any patients at all, and those apparent clinic closures were mostly small businesses. Will the bounce-back be big enough to allow them to recover—or is the damage already too great? Even before the pandemic unfolded, the rehab industry had been skewing toward more consolidation as larger corporations absorbed smaller ones. Now what? Will there be even greater incentive for small private practices to sell, given the financial toll of COVID-19?

Will consolidation or independence prevail?

Or, will government incentives for entrepreneurs—something we expect to see as the economy recovers—be enough to keep solo practitioners in business? Will a renewed desire for independence and self-sustainability be enough to motivate employees who were laid off or furloughed from large companies to leave corporate PT for good and strike out on their own (or with a partner)? Could this actually be the pendulum swinging back from consolidation toward the resurgence of independent practices? Time will tell, and we will undoubtedly know more about consumer sentiment and spending confidence when the initial government stimulus package and Medicare uplift runs out—and when the federal unemployment supplements expire.

Difficult situations often bring clarity, which means many providers may be itching to make a move that will allow them to serve who they want to serve—and treat how they want to treat—for the remainder of their careers. Others may have to make difficult choices about where to go from here if they have been forced to permanently close their practice in the wake of the pandemic. In essence, the status quo isn’t the status quo anymore, which naturally brings about instability—and change. Are you facing a fork in the road? You’re not alone, and it’s worth spending some time right now to get clear on what you believe will be the best next move for you.

What does a successful business model look like now?

States are beginning to open again, but many patients—especially those who may be higher-risk—may not want to come back to the clinic for a while longer. While telehealth is an extremely promising alternative method of care delivery—especially now—and a true game-changer for the industry, it cannot (and will not) ever replace hands-on care. So, some amalgamation of the two is necessary. Plus, most of the regulations that permit rehab therapists to perform—and bill—for these services are set to expire at the end of the public health emergency. So, what are rehab therapists to do? As I explained here, patients and providers alike will greatly benefit from having the permanent ability to provide remote services as necessary—ideally weaving telehealth into a patient’s care journey in conjunction with in-person visits so as to provide optimal value.

But getting to that place will require a shift in how we view care delivery and structure our businesses, processes, and marketing efforts. After all, we’ve historically leaned heavily on our identity as hands-on providers. Our hands are our tools. So, how do we now convince patients that we have value to offer behind a screen, too? Furthermore, how do we ensure we’re actually providing that value in practice? Of course, all of this is rather moot if we don’t successfully advocate for these telehealth expansion rules to extend beyond the shutdown.

Can we make telehealth permanent?

To that end, the APTA, WebPT, and others are currently advocating for passage of the CONNECT for Health Act, legislation that would “ease restrictions on telehealth coverage under the Medicare program.” I would encourage every PT reading this to support this effort—and to enlist your patients to do the same. While this is only one step toward securing permanent telehealth privileges at the federal level, it’s a big one—and we absolutely must strike while the iron is hot (i.e., now, while the importance of telehealth is getting global attention).

Can we get ahead of the looming pay cuts?

Speaking of advocacy, I’d be remiss not to mention that now is also the time to sound the alarms regarding the pending 8% Medicare payment cut. Unless we band together with other impacted providers to repeal this, come 2021, we’ll all face yet another major financial blow—one we may never truly recover from. Most of you know me as an eternal optimist, but I believe that this cut—on top of everything else we’re facing right now—could very well cripple the profession. And that would be absolutely devastating for providers and patients alike. So, what can you do?

We must make our collective voice heard—and we must do so now.

Are additional safety measures necessary?

Pre-pandemic, rehab therapists operated in close proximity to their patients—and their colleagues. We are a hands-on profession, after all. But how will nearly three months of “social distancing” impact our willingness to get close and personal with patients again? How will our patients—even those who are not considered high-risk—feel about being in the clinic? How do we handle the fear that will naturally linger?

For everyone’s peace of mind, additional emphasis on safety practices, hands-free intakes, and touchless payment processing may be a necessary part of doing business—and a necessary component of your patient communications. Then again, best practices for this next phase will likely vary greatly depending on the population you serve as well as where you practice. Your state may have specific guidelines for resuming operations, and the industry may very well establish its own guidelines for things like masks and personal protective equipment (PPE). Even if they aren’t established for you, though, practice leaders must make these decisions for themselves. What will you choose? What measures will you implement for your employees and patients?


There’s a lot up in the air right now—and a lot to process about the current situation and what it means for the future. And that’s on top of taking time to grieve for all that has transpired. My hope is that by starting a dialogue on what is to come, we can move forward together—we can actively shape a version of tomorrow that is supportive of our profession, our teams, and our patients. How do you think the current situation has impacted rehab therapy? Tell me your perspective in the comments below.

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Please note that developments related to the COVID-19 pandemic and associated legislative guidelines and payer policies are changing rapidly. Some of the information in this article may have changed since we last updated it on May 29, 2020. While we are doing our best to keep all of our content current, we recommend referencing the original source (e.g., government or payer guidance) whenever possible.

In these tumultuous times, prioritizing the safety of our fellow healthcare workers and patients is of the utmost importance. For that reason, many providers are shaking up their business model and reallocating resources to telehealth—especially now that CMS is reimbursing PTs and OTs for certain telehealth and remote care services. That said, for those PTs and OTs who decide to bill telehealth in the near future, there are a few crucial facts and processes to understand.

The primary purpose of this informational discussion is to explain how PTs and OTs can bill for telehealth services—not to provide recommendations on technology platforms and services used to deliver telehealth.

Please note that this article covers general telehealth principles—and that telehealth and remote care coverage and billing requirements vary widely from payer to payer (especially during the current crisis). Refer to the “Coverage” section of this article for more information, including a summary of CMS’s temporary telehealth coverage policy.

Terminology and Basic Requirements

In order to successfully navigate the rules and regulations that apply to telehealth and other virtual care services, PTs and OTs must ensure that they’re using the correct terminology.

Types of Virtual Care Services

“Virtual services” (a.k.a. remote services) is a large umbrella term that can refer to any type of service provided to patients from a different location than where the patient is located. The virtual services umbrella encompasses telehealth—which is a specific type of virtual care service—in addition to other types of long-distance care.

Because of the COVID-19 public health emergency, many payers are allowing PTs and OTs to provide and bill for an array of virtual services, including:

  • Telehealth visits (i.e., when a provider furnishes care to a patient via a live, synchronous video stream);
  • E-visits (i.e., when a provider communicates with a patient and conducts synchronous or asynchronous assessment and case management services through an online patient portal);
  • Virtual check-ins (i.e., when a provider communicates with a patient and conducts asynchronous or synchronous assessment and management services “via a number of communication technology modalities”); and
  • Telephone visits (i.e., when a provider communicates with a patient and conducts assessment and case management services through a telephone call).

Technology Requirements

Telehealth Visits

Telehealth visits require the use of a two-way, HIPAA-compliant, audio and visual technology platform. The platform can be real-time and synchronous (e.g., a live video call) or asynchronous (e.g., transmission of data—like video files—back and forth over a period of time). Many older telehealth platforms include “store-and-forward” capabilities, but states are phasing out this type of telehealth delivery. Phone calls, texts, unencrypted emails, and faxes do not meet the criteria for qualified telehealth delivery technologies. (Learn more here.)

E-Visits, Virtual Check-ins, and Telephone Visits

To successfully administer an e-visit, a provider must use a secure, HIPAA-compliant patient portal; virtual check-ins can occur via a number of different communication technologies, including a secure messaging platform and/or a live video call; and telephone services must be conducted by telephone.


State Law

Because each state has its own practice act—and many states have made their own telehealth accommodations for the pandemic—telehealth laws vary widely across the country. It is important that you familiarize yourself with your state laws, regulations, and practice act before you begin incorporating telehealth services into your practice. Start by reviewing your state practice act, and contact your state licensing board to confirm that you can provide telehealth or other virtual care services. If you cannot get in touch with a representative, contact your state APTA, AOTA, or ASHA chapter.

Therapists typically must be licensed in the state in which the patient is receiving services, which makes providing telehealth to out-of-state patients difficult. However, the APTA reports that recent Medicare actions “did include temporarily waiving Medicare and Medicaid requirements that out-of-state providers hold licenses in the state where they are providing services.” However, we strongly advise exercising caution and conferring with a legal expert before providing any services across state lines.

HIPAA Compliance

Providers are usually required to use a HIPAA-compliant telecommunications system to deliver telehealth services. However, the HHS Office for Civil Rights (OCR) has stated it will exercise discretion in enforcing that requirement in the face of the COVID-19 health crisis, opening up the potential use of more consumer-friendly platforms—like Skype and FaceTime—for telehealth delivery. Still, we do not recommend using a non-HIPAA-compliant telecommunications system to deliver telehealth, as it jeopardizes patients’ protected health information (PHI).

Additionally, the HHS OCR is only relaxing these requirements for telehealth services—not the full spectrum of virtual care services. Your e-visit and virtual check-in platforms must remain HIPAA-compliant.


It’s essential that you understand how to accurately represent your services when billing payers for telehealth or other virtual care services.


When billing for remote therapy services, you typically must notate two “site” locations:

  1. the originating site, and
  2. the distant site.

The originating site is where the patient is located—often indicated on a CMS-1500 claim form by the patient’s personal address. The distant site is where the practitioner is located, and it is indicated through various place of service (POS) codes.

Place of Service (POS) Designation

There are three POS codes that are typically used when billing remote care services:

  • 02 (telehealth)
  • 11 (office), and
  • 12 (home).

When billing Medicare for telehealth visits, virtual visits, e-visits, or telephone visits, therapists should use the place of service code that indicates where they would normally treat the patient. So, therapists should use POS 11 if they would normally treat patients in their office, and POS 12 if they would normally treat patients at the patient’s home. Do not use the 02 modifier when billing Medicare (or any other payers that are providing telehealth payment parity), as this will activate pre-PHE discounts for telehealth services.

Medicaid and other commercial payers may or may not follow this billing protocol, which is why therapists must reach out to individual payers to determine their billing preferences for telehealth and other virtual care services.


In some cases, you’ll need to use a specific modifier with your service codes to designate them as remote care services. Please note that e-visits, virtual check-ins, and telephone visits are designated as “sometimes therapy” codes, which means they will require the appropriate therapy modifier (i.e., GP, GO, or GN) when delivered by a PT, OT, or SLP.

Modifier 95

Modifier 95 indicates that a service was delivered synchronously in real-time using a HIPAA-compliant platform. While this modifier typically doesn’t apply to PT and OT services (as seen in Appendix P of the CPT® 2020 Professional Edition book), the modifier may be used with certain codes as part of the COVID-19 response period.

Medicare requires that this modifier be applied to all codes for services furnished via telehealth—but not e-visits, virtual check-ins, or telephone services.

Modifier GT

Modifier GT indicates that a service was delivered synchronously in real-time using a HIPAA-compliant platform. This code was replaced by modifier 95 in 2017—but some commercial payers still use GT for covered telehealth services.

While this modifier typically does not apply to any codes from the Physical Medicine and Rehabilitation section of the CPT manual, some non-Medicare payers may require therapists to use this modifier to designate telehealth services during the COVID-19 response period.

Modifier GQ

Modifier GQ indicates that a service was delivered asynchronously using a HIPAA-compliant platform. This is considered an “old” modifier (and an old method of delivering telehealth), and it’s slowly getting phased out.

While this modifier typically does not apply to any codes from the Physical Medicine and Rehabilitation section of the CPT manual, some non-Medicare payers may require therapists to use GQ to designate telehealth services during the COVID-19 response period.

Modifier CR

The CR modifier—which indicates that services are catastrophe/disaster-related—is not mandatory when billing Medicare for any true telehealth services, as CMS has clarified that it “is not requiring the CR modifier on telehealth services.” We are still waiting for updated written guidance from CMS regarding use of the CR modifier when billing other types of remote services. That being said, some Medicare Administrative Contractors (MACs) are advising against using the CR modifier with any remote or virtual care services, and some WebPT claims data appears to support that advice.


There are several CPT codes providers can use to bill for non-face-to-face, non-physician services. Take a look at the following guidance (much of it from the CPT manual). These guidelines contain specific details regarding the volume and timing of these services.

Telehealth Visits

Telehealth visits are limited to specific CPT codes within the 97000 series codes. Medicare, for instance, covers these codes: 97161–97164, 97165–97168, 97110, 97112, 97116, 97150, 97530, 97535, 97542, 97750, 97755, 97760, and 97761.

However, Medicaid and other payers may or may not cover these or other codes, so you need to reach out to each payer individually to determine the extent of its coverage.

When billing a telehealth visit, simply furnish the covered service (e.g., gait training), select the appropriate CPT code (e.g., 97116), apply the correct POS code and modifier as per the payer’s specifications, and complete the claim as normal.

E-Visits or Online Digital Evaluation and Management (E/M) Services

According to the CPT manual—which, by the way, we recommend reviewing in addition to this post—qualified non-physician healthcare professional online digital evaluation and management services (hereafter referred to as online digital E/M services or e-visits) are “patient-initiated digital services with qualified nonphysician health care professionals that require qualified nonphysician health care professional patient evaluation and decision making to generate an assessment and subsequent management of the patient.” Non-evaluative test result communication, appointment-scheduling, and other non-E/M communications do not fall under this classification.

These patient-initiated services must occur through a HIPAA-compliant, secure platform that allows for digital communication—and while the patient’s problem might be new, the patient should be established. Keep in mind that you must keep and permanently store visit documentation (either electronically or as a hard copy).

Online digital E/M services are billed once during a seven-day period—which begins upon your initial review of the patient’s inquiry—for all the time accumulated therin. The cumulative time for these services encompasses the time you take to:

  • review the initial inquiry,
  • assess the patient’s problem,
  • interact with other healthcare professionals regarding the patient’s problem,
  • develop management plans (including prescription generation or test ordering), and
  • communicate with the patient through HIPAA-supported digital communication tools.

Here are some other key things to know about e-visits per the waiver release:

Medicare requires PTs and OTs to use the HCPCS G-codes to indicate when they provided an online digital E/M service (a.k.a. an e-visit). Other payers (e.g., workers’ compensation or commercial payers) may ask PTs and OTs to use the HCPCS codes or the equivalent 98-series CPT codes.

Medicare Codes

This APTA release directs providers to the CMS Physician Fee Schedule lookup tool to determine the reimbursement rates for G2061-G2063 and notes that the Medicare coinsurance and deductible apply to these services.

  • G2061: Qualified non-physician healthcare professional online assessment and management service, for an established patient, for up to seven days, cumulative time during the 7 days; 5-10 minutes.
  • G2062: Qualified non-physician healthcare professional online assessment and management service, for an established patient, for up to seven days, cumulative time during the 7 days; 11-20 minutes.
  • G2063: Qualified non-physician healthcare professional assessment and management service, for an established patient, for up to seven days, cumulative time during the 7 days; 21 or more minutes.
Equivalent Non-Medicare Payer Codes

Do not bill code 98969 for an online digital E/M service, as it’s been deleted. Instead, bill one of the following codes:

  • 98970: “Qualified nonphysician health care professional online digital evaluation and management service, for an established patient, for up to 7 days, cumulative time during the 7 days; 5–10 minutes”
  • 98971: Same service description for “11–20 minutes”
  • 98972: Same service description for 21 or more minutes”
Qualifying Scenarios

If a patient reaches out within seven days of a prior in-office treatment, E/M service, or procedure—and that outreach relates to the same issue addressed during the prior treatment—then you may not bill this as a separate service. However, if the patient reaches out within seven days of a prior, unrelated in-office service, then you may bill this time as its own individual service. And finally, if another, separate E/M service occurred within seven days of your initial review of the patient’s inquiry, then you cannot bill codes G2061–G2063 or 98970–98972 again during that time period.

If, during the seven-day period encompassing an online digital E/M service, the same patient exhibits a new, unrelated issue, then the E/M time you spend on the new problem will be added to the cumulative service time of the currently active online digital E/M service time period.

Billing Caveats

Note the following caveats when billing these codes:

  • Only bill codes G2061–G2063 and 98970–98972 once every seven-day period.
  • Do not bill digital E/M services that last fewer than five minutes.
  • Do not count time as part of codes G2061–G2063 or 98970–98972 when that time is included (and billed) with other services.
  • Do not bill codes 98970 through 98972 for home and outpatient INR monitoring if you’re also billing 93792 or 93793.
  • Do not bill codes 98970 through 98972 if you’re billing one of the following codes for the same communication: 99091, 99339, 99340, 99374, 99375, 99377, 99378, 99379, 99380, 99487, 99489, 99495, or 99496.
Example Scenario

In this news release detailing CMS’s action, Alice Bell, PT, DPT, APTA senior payment specialist, provides this PT-specific example of a situation these codes might cover: “Let’s say that, as a PT, I’ve been seeing a patient for an orthopedic condition and I am progressing the patient’s exercises,” Bell said. “The patient is unable to come into the clinic but calls me to say she’s having difficulty with one of the exercises and that the other two seem to be too easy. I could arrange an e-visit with the patient and discuss her performance of the exercises. And I could then make a determination—maybe I find that the patient is performing one of the exercises incorrectly—and I could direct the patient on the correct performance. Perhaps I also determine that two of the exercises can be progressed because the patient is improving, so I could instruct the patient in the two new exercises. After that I could advise the patient to contact me for a follow-up e-visit as needed until the patient can return to the clinic.”

Virtual Check-Ins

According to CMS, virtual check-ins are “short patient-initiated communications with a healthcare practitioner” that are intended to allow patients to communicate with their healthcare provider while avoiding unnecessary trips into the clinic.

These patient-initiated services can occur through a number of communication technologies including (but not limited to) “synchronous discussion over a telephone or exchange of information through video or image…The practitioner may respond to the patient’s concern by telephone, audio/video, secure text messaging, email, or use of a patient portal.”

As with e-visits, the patient’s problem might be new, but the patient must be established prior to the check-in. Additionally, you must permanently store visit documentation (either electronically or as a hard copy).

  • G2012: “Brief communication technology-based service, e.g. virtual check-in, by a physician or other qualified health care professional who can report evaluation and management services, provided to an established patient, not originating from a related e/m service provided within the previous 7 days nor leading to an e/m service or procedure within the next 24 hours or soonest available appointment; 5-10 minutes of medical discussion.”
  • G2010: “Remote evaluation of recorded video and/or images submitted by an established patient (e.g., store and forward), including interpretation with follow-up with the patient within 24 business hours, not originating from a related e/m service provided within the previous 7 days nor leading to an e/m service or procedure within the next 24 hours or soonest available appointment.”
Qualifying Scenarios

You may bill these codes if an existing patient wants to communicate with his or her provider, and the communication is not related to a previous medical visit that occurred within the last seven days and does not lead to a visit within 24 hours (or to the soonest available appointment). Additionally, the patient must verbally consent to participate in a virtual check-in.

Telephone Services

According to the CPT manual, Telephone Visits are “non-face-to-face assessment and management services provided by a qualified health care professional to a patient using the telephone.” Special rules apply to the codes that fall under this classification. If, for example, you and a patient determine during a telephone service that he or she needs to schedule an urgent in-person visit with you within the next 24 hours (or during the next open urgent visit slot), then you would not bill the telephone code. Instead, that session’s time would count as “preservice work” for the office visit that followed.

Additionally, if the subject of the call relates to a service that you performed and reported within the past week (or within its post-op period), then the telephone service would become part of the previous service—regardless whether you called the patient, or the patient decided to call you.

  • 98966: “Telephone assessment and management service provided by a qualified nonphysician health care professional to an established patient, parent, or guardian not originating from a related assessment and management service provided within the previous 7 days nor leading to an assessment and management service or procedure within the next 24 hours or soonest available appointment; 5–10 minutes of medical discussion”
  • 98967: Same service description for “11–20 minutes of medical discussion”
  • 98968: Same service description for “21–30 minutes of medical discussion”
Billing Caveats

Note the following caveats when billing these codes:

  • Do not report CPT codes 98966 through 98968 if you’ve reported these same codes during the previous seven days;
  • Do not report 98966 through 98968 the same month you report codes 99487 through 99489;
  • Do not report 98966 through 98968 if they’re performed at the same service time as transitional care management services (99495 and 99496); and
  • Do not report codes 98966 through 98968 in conjunction with 93792 or 93793.


On March 17, 2020, CMS relaxed its remote care services requirements in response to COVID-19. Per those updates, Medicare began reimbursing PTs, OTs, and SLPs for e-visits, virtual check-ins, and telephone visits that occurred on March 6 or later. On April 30, 2020, CMS relaxed its telehealth policies and added PTs, OTs, and SLPs to the list of qualified telehealth providers, retroactive to March 1, 2020. As such, rehab therapists can now bill Medicare for traditional telehealth services.

These updates did not apply to Medicaid or commercial insurances—however, many Medicaid programs and commercial payers have loosened their own remote care coverage policies and now allow PTs, OTs, and SLPs to administer some form of remote care. Reach out to your payers and verify whether or not they cover remote services for rehab therapy—and what those services are. If your payers do not cover virtual care, you will likely need to look to your patients to pay for these services.


As with all medically necessary services, third-party payer coverage is only part of the patient’s decision process. Consider dry needling: non-coverage in that case creates an opportunity to discuss the benefits of the service.

If a service is not covered by a payer for which you are a preferred provider, you may collect payment directly from patients at the time of service. However, before you do this:

  1. set a fee schedule for your telehealth services, and
  2. create a transparent billing process for your patients.

Notify these patients (in writing) that telehealth services are not covered by their payer, and clearly establish the projected cost as well as when you expect payment. If you are not a preferred provider, you are not bound by the payer’s noncoverage of your services.

Remember, because Medicare now covers all of the remote care services discussed above, Medicare beneficiaries may not pay for these services out-of-pocket.

Payer Policy Restrictions

Be sure to check payers’ medical policies to ensure they do not classify telehealth therapy services as “not medically necessary” or “effectiveness not established.” If either of these classifications apply, then you cannot balance bill the patient for telehealth services. If you proceed and bill these services to that payer, then it will assign the balance to the practice or individual therapist—not the patient. And remember, if you’re a preferred provider for a commercial plan, your contract likely requires you to bill all services to that payer so it can determine the patient’s liability—meaning you cannot simply collect cash from the patient upfront to bypass submitting a claim to the payer.

Evolving Standards

Until the emergence of the COVID-19 health crisis, there was very limited payer coverage for PT and OT telehealth or remote monitoring. However, the current situation is fluid—and many payers (including Medicare) currently allow telehealth practice in light of COVID-19’s public health implications. Stay informed about the evolving situation (and consume accurate information) by subscribing to updates from:

To help rehab therapists during this time of crisis, WebPT has provided a wealth of information about telehealth and business continuity. If you would like to learn more about these topics, I urge you to review our resources in addition to those provided by CMS, the APTA, the AOTA, and your payers.

The post Billing for PT and OT Telehealth Services During the COVID-19 Response appeared first on WebPT.

This post was originally published on this site

Change is never easy, which is something every rehab therapy practice can attest to right now. The COVID-19 pandemic has forced a whirlwind of change at every level of rehab therapy—from doubling down on sanitization practices to implementing telehealth services. Now that things seem to be settling into a new normal, practices must contend with another type of change: adjusting their approach to marketing. However, change isn’t necessarily a bad thing, and with the right strategy and a little marketing finesse, clinics can take this opportunity to get their message in front of the right patients. To that end, here are some steps rehab therapy practices should take when marketing their services post-COVID:

Communicate with patients and referral sources.

The success of any relationship hinges on communication—and that includes your relationship with potential patients. Despite the fact that many state and local governments have lifted stay-at-home orders, there’s still a high number of active COVID-19 cases nationwide, which means there’s still a chance for infection—particularly among high-risk individuals. It also means many people remain nervous about exposure. For that reason, it’s crucial that you tell patients what you’re doing to keep them safe. In this blog post, we advise that practice leaders “map out a game plan for reopening your practice to the public.” Part of that plan should include updated safety and sanitation guidelines that align with CDC recommendations. Once you have this plan in place, communicate it—as well as any remote care service options (i.e., home visits or telerehab)—to patients on all of your marketing channels, including your clinic’s:

  • social media pages,
  • website, and
  • online and print ads.

Re-engage past patients.

Next, start contacting your past patients. In an interview with WebPT, Simon Hargus, PT, DPT, OCS, MBA, the owner of First Settlement Physical Therapy (FSPT), stresses the importance of this: “You’re going to need patients in order to ramp your practice back up. I’ve been keeping a running list of folks who want to come back (but aren’t doing telehealth or home PT). We plan on touching base with them—as well as those who were interested in workshops—regularly. We also will reach out to past patients.” Specifically, we suggest sending these patients an email or reaching out via text or telephone and explaining the safety precautions your clinic is taking.

You should also promote any alternative treatment modalities—like telehealth—that can help patients avoid potential exposure. For example, if your practice has implemented telehealth services, you should:

  • educate patients on the benefits of telehealth,
  • explain how easy it is to use, and
  • provide examples of patients using telehealth successfully (if possible).

Telehealth offers patients a safe, hands-off option for receiving rehab therapy services, and it could set you apart from other providers who haven’t made remote therapy part of their practice’s service repertoire.

Update your Google listing.

You’ll also need to update your online listings. As the healthcare marketing experts at Full Meda explain here, “Google My Business is also now offering the ability to add two links to any of your local listings. This includes a special link to COVID-19 information and another link to Telehealth information on your website.” Take advantage of this opportunity to not only educate patients but also boost your online visibility when patients search for telehealth services.

Reach out to your referral sources.

Hargus also suggests connecting with your referral sources to let them know you’re open for business. “It’ll be important once the dust settles to focus on warming up those referral relationships again,” he said. “A lot of the hospital referral staff—even some physicians—have gotten moved or have new preferred ways of being contacted.” Additionally, in areas that have been hit hard by the novel coronavirus, hospital rehabilitation centers may be overtaxed by post-COVID patients in need of PT as they come off ventilators, so offering your services to these facilities may come as a welcome relief to them.

Promote unique services.

As life returns to normal and patients begin looking for services to accommodate their needs, practices should promote any unique services that set them apart from their competitors—including gyms and wellness facilities—on their marketing channels (e.g., social media posts, website, print and media advertising, etc.). After all, the fallout from the pandemic has sent shockwaves throughout all areas of the economy, so the competition will be steep as business picks back up. However, as healthcare providers, rehab therapists could have a distinct advantage when it comes to alleviating patient anxieties over safety and sanitization practices. So, this is something practices should take into consideration when promoting any ancillary services such as fitness classes or massage.

Work on your reputation.

Perhaps one of the most important pieces of digital marketing is your clinic’s online reputation. As we’ve mentioned in the past, more and more patients are turning to Google to find their next rehab therapist, and one of the first things they’ll look at when making a decision is your online reviews. So, reach out to patients who received treatment during the pandemic and ask them to leave a review on Yelp, Google, or Facebook. This is easier to do if you track patient satisfaction or, even better, your patients’ Net Promoter Score® (NPS). That way, you can easily pick out who your happiest patients are, and thus, approach patients who are the most likely to leave you a glowing review.

Take advantage of discounted advertising.

Finally, review your clinic’s current marketing budget and look for opportunities to maximize your advertising spend. In response to the COVID-19 pandemic—and the resulting economic impact—many media outlets may be offering discounted pricing options. So, reach out to any publications or media platforms that are likely to reach your target audience (e.g., local TV stations, community newspapers, Spotify, etc.) and inquire about available discounts. We suggest doing this sooner rather than later to capitalize on high availability.

Change is inevitable—and necessary. As the world emerges from the COVID-19 pandemic, the changes rehab therapists have made—and will make—to their practices will not only ensure the safety of their patients, but also enhance their reputation as essential healthcare providers. Got any burning questions about marketing your practice post-COVID? Let us know in the comment section below!

The post How to Adjust Your Clinic’s Marketing Strategy in Light of COVID-19 appeared first on WebPT.