SNF therapy advocates asked (and asked, and asked, and asked….) and yesterday, CMS answered!

Telehealth therapy services can be provided to SNF residents under Medicare Part B {at least for now}.

On 5/27/20, CMS released an updated version of the Medicare Fee-for-Service Billing FAQ Document {AKA Medicare Part B}. This Document replaced the FAQ Document released March 15th, and contained the information SNF therapy professionals have been waiting for. On the last 2 pages of this 71 page document, CMS included a new section “FF: Outpatient Therapy Services,” which contains 3 questions:

  1. Can outpatient therapy services that are furnished via telehealth and separately paid under Part B, be reported on an institutional claim (e.g., UB-04) during the COVID-19 PHE?
  2. Can therapy services furnished using telecommunications technology be paid separately in a Medicare Part A skilled nursing facility (SNF) stay?
  3. Can outpatient therapy services be furnished and paid separately for patients receiving Medicare home health services?

CMS answered “Yes” to question 1, “Can outpatient therapy services that are furnished via telehealth and separately paid under Part B be reported on an institutional claim (e.g., UB-04) during the COVID-19 PHE?” Specifically, CMS’s answer was as follows:

Outpatient therapy services that are furnished via telehealth, and are separately paid and not included as part of a bundled institutional payment, can be reported on institutional claims with the “-95” modifier applied to the service line. This includes:

  • Hospital – 12X or 13X (for hospital outpatient therapy services);

  • Skilled Nursing Facility (SNF) – 22X or 23X (SNFs may, in some circumstances, furnish Part B physical therapy (PT)/occupational therapy (OT)/speech-language pathology (SLP) services to their own long-term residents;

  • Critical Access Hospital (CAH) – 85X (CAHs may separately provide and bill for PT, OT, and SLP services on 85X bill type);

  • Comprehensive Outpatient Rehabilitation Facility (CORF) – 75X (CORFs provide ambulatory outpatient PT, OT, SLP services);

  • Outpatient Rehabilitation Facility (ORF) – 74X (ORFs, also known as rehabilitation agencies, provide ambulatory outpatient PT & SLP as well as OT services)

  • Home Health Agency (HHA) – 34X (agencies may separately provide and bill for outpatient PT/OT/SLP services to persons in their homes only if such patients are not under a homehealth plan of care)

The answers to Questions 2 and 3, in a nutshell, was “no.”

CMS states that this new FAQ supplements the previously released FAQs: 1135 Waiver, and notes that in many instances, the general statements of the FAQs referenced have been superseded by COVID-19-specific legislation, emergency rules, and waivers granted under section 1135 of the Act specifically to address the COVID-19 public health emergency (PHE). CMS also reminds us that the policies set out in this FAQ are effective ONLY for the duration of the PHE unless superseded by future legislation.

For additional information on Part B telehealth and virtual services for SNF therapy, please reference our 2 prior articles:

For continued updates on COVID-19 changes impacting SNF therapy, visit our COVID-19 SNF Resource Page.

As always, if you have any questions, please send them to our Just Ask Q&A Forum and we will be glad to help you.

In Your Corner,


Dolores Montero, PT, DPT, RAC-CT, RAC-CTA

SNF Rehab & MDS Compliance Team

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