Win: Medicare Contractors Will Continue to Pay for Remote Therapeutic Monitoring

APTA

More good news for providers and patients under Medicare: Medicare administrative contractors, or MACs, will follow the recommendations of APTA and other organizations and not move toward developing local coverage determinations for remote therapeutic monitoring. The win came after APTA and others participated in a meeting of MACs in February.

What it means: For the time being, Medicare fee-for-service beneficiaries can expect coverage of RTM and remote physiologic monitoring procedures, and PTs can continue to bill for RTM codes under the Medicare Physician Fee Schedule. The decision was announced in a recent email from the MACs and a post on MAC websites.

The decision came after a Feb. 28 meeting of the Multijurisdictional Contractor Advisory Committee to discuss the potential development of a local coverage determination, or LCD, for RTM. During the meeting, the committee members specifically sought input from APTA and other organizations on the pros and cons of adopting an LCD.  

Alice Bell, PT, DPT, APTA senior specialist for health policy and payment, served as a subject matter expert panelist and offered input on the clinical importance of RTM along with evidence to support its use by PTs. Other APTA representatives were on hand to add to Bell's perspective, advocating against adopting local policies that would create patchwork coverage.

"Remote therapeutic monitoring provides an opportunity to enhance the care offered by physical therapists," Bell said. "It can be a very useful tool to ensure that the plan of care is optimized, goals are achieved in a timely manner, and a patient is able to sustain self-management during the course of and after discharge from therapy, and APTA is pleased that the MACs recognize the patient benefits."

PTs were first added to the list of providers able to bill for RTM in 2022. Since then APTA has successfully worked with the U.S. Centers for Medicare & Medicaid Services around code denials made in error by some MACs. The association also offers a practice advisory on RTM, an APTA member benefit that includes background on the codes, descriptions of each, documentation requirements, and guidance on which codes are subject to payment adjustment under the PTA differential system, as well as real-world examples that clarify application.

Big Win: CMS Extends Temporary Telehealth Use to All Facility-Based Settings

APTA

In what now amounts to a total reversal of its initial post-public health emergency policies around telehealth, the U.S. Centers for Medicare & Medicaid Services has listened to APTA and other organizations and will allow the provision of telehealth services across a range of facilities, just as they were permitted during the PHE. The major advocacy win means that PTs in skilled nursing facilities, home health, and rehab agencies can continue to provide remote services under Medicare Part B — although CMS has yet to say when those allowances might end.

As with an earlier clarification around hospital-based settings, the latest news from CMS comes by way of an FAQ document on post-PHE policies (see question 22). In the latest iteration of the resource, CMS says that therapy providers working across the range of facility settings can continue to provide telehealth services as they did via waivers granted during the PHE. The announcement follows an earlier, more limited reversal that applied only to telehealth provided in hospital-based facilities.

Originally, CMS' post-PHE telehealth policies appeared to exclude any facility-based provision of telehealth from coverage if that facility used a particular claim form, the UB04. APTA was among the first organizations to call attention to the inconsistencies and patient access problems with this position, and was joined by the American Speech-Language-Hearing Association and the American Occupational Therapy Association in advocacy to press CMS to maintain telehealth allowances across the board. While CMS warned that it could take some time to provide definitive guidance, in the end the agency's decisions arrived relatively quickly.

While the guidance from CMS is clearly good news for the physical therapy community and its patients, one major detail was left out — namely, if and when these telehealth allowances would end. In its earlier hospital-based telehealth decision, CMS stipulated that telehealth could continue through the end of 2023 in those settings. That ending date, opposed by APTA, doesn't jibe with telehealth end dates for PTs and PTAs in private practices, which are expected to be extended through Dec. 31, 2024. APTA, ASHA, and AOTA are pushing for answers, which CMS will most likely provide when it issues the 2024 proposed Medicare Physician Fee Schedule. Meanwhile, APTA and other organizations are pushing for lawmakers to permanently include PTs and PTAs in the list of providers allowed to provide telehealth services under Medicare.

"The conversations we were able to have with representatives from [the U.S. Department of Health and Human Services] were extremely beneficial in helping CMS understand why it's so important to maintain telehealth allowances after the PHE, particularly for patients in rural and underserved communities," said Kate Gilliard, JD, APTA's director of health policy and payment. "We're extremely happy that CMS sees the value in continuing coverage."