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I heard we can now provide physical therapy, occupational therapy and speech therapy services through telehealth, is that correct? Are there any restrictions on who can bill Medicare for these services?

Within it’s COVID-19 Interim Final Rule released on March 30th CMS did expand its list of covered telehealth services to include the physical therapy, occupational therapy and speech therapy CPT codes listed below. However, it is extremely important to note that CMS has not added Physical Therapists, Occupational Therapists or Speech Language Pathologists to its list of approved telehealth provider types — meaning CMS will not cover the therapy codes noted below when provided via telehealth and rendered by a Physical Therapist, Occupational Therapist or Speech Language Pathologist. The therapy codes listed below will only be covered by Medicare as telehealth services if rendered by one of the CMS approved telehealth provider types – also outlined below.

  • CMS Approved Telehealth Therapy Services:
    97161-97168, 97110, 97112, 97116, 97535, 97750, 97755, 97760, 97761, 92521-92524, 92507
  • CMS Approved Telehealth Provider Types (subject to individual state laws):

Physicians, Nurse Practitioners, Physician Assistants, Nurse Midwives, Clinical Nurse Specialists, Certified Registered Nurse Anesthetists, Clinical Psychologists,  Clinical Social Workers, Registered Dietitians, nutrition professionals and Residents (depending on the scope of the services rendered by the Resident additional requirements may apply to this specific provider type)

CMS COVID-19 Interim Final Rule, “Medicare and Medicaid Programs; Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency”: https://www.cms.gov/files/document/covid-final-ifc.pdf

“In light of the PHE for the COVID-19 pandemic, we believe that the risks associated with confusion are outweighed by the potential benefits for circumstances when these services might be furnished via telehealth by eligible distant site practitioners. We believe this is sufficient clinical evidence to support the addition of therapy services to the Medicare telehealth list on a category 2 basis. However, we note that the statutory definition of distant site practitioners under section 1834(m) of the Act does not include physical therapists, occupational therapists, or speech-language pathologists, meaning that it does not provide for payment for these services as Medicare telehealth services when furnished by physical therapists, occupational therapists, or speech-language pathologists”