Western District News
MPTA COVID-19 Consolidated Resources and Updatesposted: March 26, 2020
In order to consolidate critical information, MPTA will be posting and updating information only in this area. The information below is provided in topic areas based on inquiries and issues that are most pressing.
MPTA sent a letter to the Governor on March 20 requesting relief in many of the areas outlined below.
APTA has provided broad guidance for members to consider when deciding whether or not to provide in-person/clinic-based care. http://www.apta.org/Coronavirus/Statement/. APTA President Sharon Dunn also provided further clarification in a letter to members.
On March 23, Governor Whitmer issued a Stay Home, Stay Safe Executive Order. In that Executive Order there are exemptions for those who provide essential services. Health care, including physical therapy, is an essential service as noted in this Department of Homeland Security Memo Download file
General guidance from various sources suggests that health care providers should defer all in-person, non-essential health care delivery. However, defining when care is non-essential for a given patient is not easy. This decision should be made on a case-by-case basis relative to risk. Some patients will absolutely decline without care and physical therapy interventions can decrease the burden on other health care providers. In-person care for these patients should only be considered if e-visits and telehealth are not available or appropriate, if you have adequately screened risk of infection/exposure of both staff and patients using a 14 day look-back period, screened for the presence of current symptoms, can ensure adequate distancing from others in the clinic space, and have implemented effective environmental and equipment cleaning practices. Although no Executive Order yet exists regarding limited operations for outpatient clinics that are not state-run, you should ensure that you can safely deliver in-person care for those with essential health care needs.
This is not business as usual and requires ethical evaluation of the risk of exposure to COVID-19 compared to the benefit of therapy treatment requiring in-person care. Providing essential care means:
- Limiting the volume of in-person visits to patients whose care cannot be postponed or provided via e-visits/telehealth to reflect implementation of the Michigan Executive Order to "stay home, stay safe, save lives"
- Providing only that in-person care which prevents decline and reduces the burden on other healthcare providers
- Only providing 1-on-1 care and avoiding the use of group and concurrent therapy
- Establishing a staff workplace design to adhere to physical distancing guidelines
- Adopting remote clerical processes to eliminate patient exposure to non-clinical staff during in-person visits
- Adequately screening for risk of infection/exposure and presence of current symptoms of both staff and patients
MPTA is not a regulatory body and therefore cannot require any specific actions. However, the State of Kentucky did offer regulatory guidance to providers in that state to assist them in the exercise of their judgment. These guidelines may be helpful for physical therapists and physical therapist assistants in Michigan in deciding how their practice should be modified to ensure the safety and well-being of Michigan’s citizens.
Kentucky Cabinet for Health and Family Services Guidelines Download file
E-Visits and Telehealth in Michigan/Payer Updates Related to COVID-19
From a regulatory perspective, physical therapy services via Telehealth are allowed: For full information download this document:
The following payers have approved either e-visits or telehealth:
March 22, the Centers for Medicare & Medicaid Services (CMS) announced unprecedented relief for the clinicians, providers, and facilities participating in Medicare quality reporting programs including the 1.2 million clinicians in the Quality Payment Program and on the front lines of America’s fight against the 2019 Novel Coronavirus (COVID-19).
Specifically, CMS announced it is granting exceptions from reporting requirements and extensions for clinicians and providers participating in Medicare quality reporting programs with respect to upcoming measure reporting and data submission for those programs. The action comes as part of the Trump Administration’s response to 2019 Novel Coronavirus (COVID-19).
Health Alliance Plan of Michigan: Download file
BCBSM: BCBSM has informed MPTA that it will cover CPT Codes 97110, 97112, 97116, 97530 and 97535 via telehealth effective for both commercial and MA population until June 30. Unfortunately, this policy decision has not been finalized or implemented and we have not been given any further information. Until official notification is provided, providers should not bill for telehealth services. MPTA continues to advocate for coverage of telehealth services. We will provide additional information as soon as it is received.
Priority Health: MPTA has asked for coverage of CPT codes that could feasibly be delivered via telehealth (97110, 97112, 97116, 97530, 97535) using the 02 place of service modifier. A final decision is still pending, though they have indicated that they likely will only cover the G codes consistent with CMS.
Meridian: MPTA has asked for coverage of CPT codes that could feasibly be delivered via telehealth (97110, 97112, 97116, 97530, 97535) using the 02 place of service modifier. A final decision is still pending.
Medicaid: MDHHS has published a Bulletin Download filthat effectively states that telehealth physical therapy is NOT covered. MPTA immediately responded to this Bulletin.Click here to see the communication: Download file
CIGNA: APTA can confirm that Cigna has established a telehealth policy for PT, OT, and ST in light of COVID19. Please go the link below. https://static.cigna.com/assets/chcp/resourceLibrary/medicalResourcesList/medicalDoingBusinessWithCigna/medicalDbwcCOVID-19.html
Click on Virtual Care Guidelines then Click on Virtual Care for Physical, Occupational, and Speech Therapy Services
Specifically, as it relates to Physical Therapy the following codes can be billed through May 31, 2020 and will be reimbursed at the standard fee schedule. Providers will need to append the GQ modifier and bill with a standard place of service code.
97161 PT eval low complex 20 min (Telephonic or virtual)
97162 PT eval mod complex 30 min (Virtual)
97110 Therapeutic exercises (2 unit limit)
UnitedHealthcare: Announcement posted March 26:
UnitedHealthcare will reimburse physical, occupational and speech therapy telehealth services provided by qualified health care professionals when rendered using interactive audio/video technology. State laws and regulations apply. Benefits will be processed in accordance with the member’s plan.
This change is effective immediately for dates of service March 18 through June 18, 2020.
It is important to remind providers that care provided via telehealth must be safe and appropriate to the clinical situation and must continue to meet all associated standards of care. https://www.fsbpt.org/Portals/0/documents/free-resources/TelehealthInPhysicalTherapy2015.pdf
Relief for Employers
Relief for small business owners is evolving at a rapid pace at both the federal and state levels.
At the state level, MPTA has been working with the Director of the Department of Labor and Economic Opportunity to share the concerns of owners of PT practices of varying sizes. There is no one-size-fits-all solution, but resources that may be helpful include:
Michigan Small Business Relief Fund:
Michigan Guidance Regarding Layoffs:
Contact the Office of Employer Ombudsman on-line through your MiWAM account or at 855-484-2636
APTA is encouraging congress to urgently pass legislation to expand locum tenens and expand financial grant relief beyond Economic Injury Disaster Loans to assist small businesses such as outpatient physical therapy clinics and small home health agencies, so that they can meet short-term obligations, such as payroll and rent, as well as costs associated with ensuring that they are able to comply with Centers for Disease Control and Prevention recommendations. Go to the Legislative Action Center to ask your legislators to pass this legislation now. https://www.apta.org/TakeAction/
Additional proposed legislation in Congress would provide loans with 100 percent federal guarantees to small employers who keep their workers on payroll during the crisis. If small business owners avoid laying off workers, the loans would be 100 percent forgiven.
The loans would be permitted to cover payroll expenses, sick leave, supply chain disruptions, mortgage payments and other debts. It includes $240 million in grants for small business development centers and women’s business centers for counseling and it would provide loans with 100 percent federal guarantees to small employers who keep their workers on payroll during the crisis. If small business owners avoid laying off workers, the loans would be 100 percent forgiven.
Student Loan Relief:
Effective March 20, all borrowers with federally held student loans will automatically have their interest rates set to 0% for a period of at least 60 days. In addition, each of these borrowers will have the option to suspend their payments for at least two months to allow them greater flexibility during the national emergency. This will allow borrowers to temporarily stop their payments without worrying about accruing interest.
Additional Student Resources are found here: https://studentaid.gov/announcements-events/coronavirus
Special COVID-19 Video Message from MPTA President Mile Shoemakerposted: March 20, 2020
Please click HERE to view this special message from the MPTA President, Mike Shoemaker.
Tricare Update - PTA Services will be covered as of April 16, 2020posted: March 16, 2020
APTA announced that the Department of Defense (DoD) released a final rule to add licensed or certified PTAs as TRICARE-authorized providers operating under the same qualifications established by Medicare. Services must be furnished under the supervision of a TRICARE-authorized licensed physical therapist.
This rule says that direct supervision will be required in a private practice setting. General supervision will be required in all settings other than private practice. These guidelines are in line with the Medicare supervision requirements.
APTA has been working for the recognition of PTAs as TRICARE authorized providers for many months and we appreciate the dedication and hard work of the PTAs, PTs, and physical therapy students who submitted comments on the proposed rule.
The rule is effective on April 16, 2020.
For questions regarding the rule, please contact email@example.com.
MPTA Requests Telehealth Coverage for Servicesposted: March 15, 2020
MPTA initiated urgent dialogue with Priority Health and BCBSM regarding payment for telehealth-based PT services to facilitate the use of social distancing while continuing to deliver PT care for those who are unable to delay their care and who are among the most vulnerable.
MPTA has also initiated discussions with Meridian Health about coverage for telehealth and direct access.
Updates will be provided as soon as they are available. The letters can be viewed here:
BCBSM Download file
Telehealth in Michigan - Information for your practiceposted: March 15, 2020
Can a physical therapist in Michigan provide care via telehealth?
Starting with professional scope of practice, APTA Policy is clear that telehealth can be an appropriate model of care delivery of physical therapy services (http://www.apta.org/uploadedFiles/APTAorg/About_Us/Policies/Practice/TelehealthHODPolicy.pdf#search=%22telehealth%22).
Further, the FSBPT has a resource paper on important considerations for physical therapists utilizing telehealth (https://www.fsbpt.org/Portals/0/documents/free-resources/TelehealthInPhysicalTherapy2015.pdf).
Regulatory scope of practice is almost always more limiting than professional scope of practice, but there are also many instances of the Physical Therapy Section of the Public Health Code being silent on specific issues. So when you look at the Public Health Code, there is nothing in the Physical Therapy section that specifically permits or prohibits telehealth. But a quick search of the General Provisions, which apply to all licensed health professionals, reveals that telehealth is permitted to be provided by licensed health professionals in Michigan: (http://www.legislature.mi.gov/(S(0dsbzvzpxu4lawibsw5ym4q2))/mileg.aspx?page=GetMclDocument&objectname=mcl-368-1978-15-161)
From a state regulatory scope of practice perspective, telehealth is permitted by physical therapists:
As used in this section and sections 16284 to 16288:
(a) "Health professional" means an individual who is engaging in the practice of a health profession.
(b) "Prescriber" means that term as defined in section 17708.
(c) "Telehealth" means the use of electronic information and telecommunication technologies to support or promote long-distance clinical health care, patient and professional health-related education, public health, or health administration. Telehealth may include, but is not limited to, telemedicine. As used in this subdivision, "telemedicine" means that term as defined in section 3476 of the insurance code of 1956, 1956 PA 218, MCL 500.3476.
Further, the Insurance Code (MCL 500.3476) offers additional guidance:
(1) An insurer that delivers, issues for delivery, or renews in this state a health insurance policy shall not require face-to-face contact between a health care professional and a patient for services appropriately provided through telemedicine, as determined by the insurer. Telemedicine services must be provided by a health care professional who is licensed, registered, or otherwise authorized to engage in his or her health care profession in the state where the patient is located. Telemedicine services are subject to all terms and conditions of the health insurance policy agreed upon between the policy holder and the insurer, including, but not limited to, required copayments, coinsurances, deductibles, and approved amounts.
(2) As used in this section:
(a) After December 31, 2017, "insurer" includes a nonprofit dental care corporation operating under 1963 PA 125, MCL 550.351 to 550.373.
(b) "Telemedicine" means the use of an electronic media to link patients with health care professionals in different locations. To be considered telemedicine under this section, the health care professional must be able to examine the patient via a real-time, interactive audio or video, or both, telecommunications system and the patient must be able to interact with the off-site health care professional at the time the services are provided.
Further information regarding "scope of practice."
Expanding your professional boundaries is the epitome of professional practice because a good clinician is always learning. As you consider the directions in which you would like to grow, you also need to understand the legal/regulatory constraints that may impact your decision.
“Scope of Practice” is a broad term that includes: 1) professional scope of practice as defined by CAPTE entry-level education standards, APTA positions and policies, and FSBPT resource papers, 2) regulatory scope of practice as defined by state law, and 3) personal scope of practice as defined by your individual experiences and professional development. Other factors that affect your practice include third party payer regulations and facility policies.
All of the resources for determining professional scope of practice can be found at: http://www.apta.org/ScopeOfPractice/. Among the numerous links available is the link to the APTA Policies related to practice (http://www.apta.org/Policies/Practice/).
Resources related to regulatory scope of practice in MI can be found at: https://www.michigan.gov/lara/0,4601,7-154-72600_72603_27529_27549---,00.html. Especially important are the links to the Physical Therapy section of the Public Health Code, the General Provisions of the Public Health Code, the Administrative Rules, and the FAQs. Licensing and Regulatory Affairs (LARA), in consultation with the MI Board of Physical Therapy (aka the PT Licensure Board), promulgate the administrative rules and the FAQs which are an interpretation/application/operationalization of the Public Health Code, and have the force of law. Navigating the legalese of regulatory scope of practice can be challenging, but MPTA is here to help. One of the many member benefits is the ability to ask MPTA leaders questions about practice. Although the MPTA cannot offer legal advice, it can provide highly informed opinion to get you going in the right direction.
National Telehealth: It would appear that despite the remarks from the President on expanding the use of telehealth, the declaration will not provide for a waiver to expand authorized health care professionals to deliver services via telehealth under Medicare. APTA will continue to press Congress to include legislative language that waives the current restrictions on PTs and other health care providers from delivering services via telehealth under Medicare to assist with the current COVID 19 situation.