As the novel coronavirus (COVID-19) continues to spread across the country at a rapid rate, occupational therapy practitioners may be wondering whether they can utilize telehealth to continue providing occupational therapy (OT) services while mitigating transmission of the virus, particularly to more vulnerable populations. While it may seem an easy fix and an obvious solution, there are still some obstacles surrounding providing OT via telehealth.
Although Congress recently passed legislation providing additional money and loosening the restrictions on telehealth in Medicare, this legislation only serves to ease access to existing telehealth services—it does not expand the definition of who can provide telehealth services. Currently, the statutory definition of a telehealth-eligible provider does not include occupational therapy practitioners. The legislation also does not address the CONNECT Act, which would expand service options via telehealth, including OT. The Centers for Medicare & Medicaid Services (CMS) has issued additional guidance and information regarding the current availability of telehealth services in response to the COVID-19 outbreak. A CMS fact sheet outlines payment and coverage relative to COVID-19, including telehealth. For Medicare Advantage plans, CMS has also released a memorandum that outlines the requirements, obligations, and flexibilities afforded to the Medicare Advantage organizations during the outbreak. For example, Medicare Advantage plans may expand their coverage of telehealth services during the outbreak without penalty or enforcement actions from CMS.
For Medicaid and CHIP programs, many OT services are already reimbursable via telehealth. However, there is variation from state to state. In those circumstances, practitioners are urged to contact their state Medicaid agency with any questions. Some state OT boards do have rules in place that dictate how a licensee should use a telehealth platform to provide services but do not necessarily allow for Medicaid reimbursement for OT. Some states do allow for reimbursement, but do not delineate practice standards in the Board rules. The general assumption is that if the state does not explicitly restrict telehealth services by a practitioner, and the practitioner is licensed in the state where the patient is located, they can provide services via telehealth; however there is no guarantee they will be reimbursed for those services.
Likewise, with private/commercial payers, coverage for OT services provided via telehealth will vary by plan. Many plans are electing to waive cost-sharing (co-payments, deductibles, and co-insurance) or otherwise expanding access for telehealth services—for example, CVS/Aetna is waiving co-payments for telemedicine visits for any reason under certain circumstances, and Blue Cross and Blue Shield is encouraging its member plans to provide expanded access to telehealth services. Some plans are implementing this just for services provided to individuals diagnosed with COVID-19, but some are doing so for all currently covered telehealth services, no matter the diagnosis. Whether OT is included depends in part on whether the state scope of practice allows for OT to be provided via telehealth and also on the plan policies and benefits structure. Practitioners are encouraged to contact the plans directly to determine the plans’ current policy and approach to the provision of OT telehealth services.