Payment and Coverage Considerations for Telepractice Services During COVID-19
Updated January 11, 2023
Audiologists and SLPs should be aware of the following payment and coverage issues as you consider implementing telepractice as an alternative service delivery model during the COVID-19 pandemic. ASHA also provides COVID-19 updates, including public policy updates, telepractice resources, clinical considerations, and other important resources to help you through this time.
On this page:
- Changes to Telepractice Coverage Due to COVID-19
- Getting Started
- When Telepractice Isn't an Option
- What ASHA is Doing to Help (and What You Can Do Too!)
- Questions?
Changes to Telepractice Coverage Due to COVID-19
Many payers have expanded telepractice services to audiologists and SLPs but policies continue to change as the pandemic continues.
Many states and payers have loosened telepractice policies or expanded coverage to additional provider types during the COVID-19 pandemic, including audiologists and SLPs. Remember, telepractice guidelines vary among payers (Medicare, Medicaid, commercial insurers) and many continue to update their policies and coverage, so it's important to verify with specific payers whether you are starting or continuing services. You should also be aware of changing state practice laws and regulations [PDF].
ASHA continues to advocate for appropriate coverage of telepractice services across payers.
Clinicians are encouraged to monitor when current expansions related to the public health emergency (PHE) are set to end.
(updated 1/11/2023)
Clinicians should carefully monitor when federal and state PHEs will end, as dates could vary and will impact the availability of telepractice services in health care and educational settings.
The U.S. Department of Health and Human Services (HHS) must extend the federal PHE related to COVID-19 every 90 days to maintain certain health care flexibilities and waivers, including temporary coverage of audiology and speech-language pathology services provided via telehealth. The PHE has been in place since January 27, 2020, and has been renewed several times during the course of the pandemic. The latest HHS extension for the PHE is effective through April 11, 2023.
In a letter to the state Governors, the Administration has indicated they will give at least a 60-day notice before the PHE ends. In addition, the Consolidated Appropriations Act, 2023, extends the authority for audiologists and speech-language pathologists to provide telehealth services to Medicare beneficiaries and continues waivers of geographic and originating site restrictions through December 31, 2024. Please continue to monitor ASHA's 2023 federal PHE update page for the latest information.
States may also set different dates for ending the PHE locally. This means that temporary state licensing, Medicaid, and local education agency expansions could end at different times than federal expansions.
Commercial payers may also opt to maintain expansions beyond state or federal PHE dates.
See also:
- State telehealth, out-of-state regulations may change as PHEs end
- What to expect at the end of the PHE: Maintaining compliance with state, federal, and payer laws and requirements
Work directly with your facility to determine coverage and payment for telepractice services provided in hospital outpatient settings and inpatient settings.
Most payers are focused on expanding telepractice services in non-facility outpatient settings (e.g., private practices, clinics). However, many clinicians working in inpatient or facility-based settings may have questions about coverage and payment as they begin using telecommunication technology to deliver services to patients. Please work with your facility, billing personnel, administrators, and/or compliance officer to determine the payer’s billing and coverage policies for inpatient or facility-based services, as this may differ from outpatient non-facility billing and can change quickly during this time. ASHA continues to work with payers on comprehensive coverage of telepractice services across settings and will post information as we learn more about inpatient or facility-based billing.
Medicaid, TRICARE, and Commercial Plans
There has been significant progress expanding telepractice services across state Medicaid programs and commercial insurance plans, however some states and payers may be pulling back expansions due to changes in state and local PHE declarations.
There has been significant progress expanding telepractice coverage for audiologists and SLPs as states, Medicaid programs, commercial payers, and TRICARE worked to curb the spread of COVID-19. Many private payers and Medicaid programs that have expanded telepractice services during the COVID-19 pandemic. However, as state and local PHEs expire, some state licensing laws and regulations and payer policies that allowed more expansive use of telepractice services may change. Clinicians should carefully track changing requirements at both the state [PDF] and payer level.
Medicare
Medicare covers telepractice services provided by audiologists and SLPs during the PHE.
Medicare allows audiologists and SLPs to provide telehealth services to Medicare Part B (outpatient) beneficiaries for the duration of the PHE. See ASHA’s webpage on Medicare coverage of telehealth services during COVID-19 for details.
Although the list of covered audiology and speech-language pathology services is not comprehensive, CMS has included many key audiology and speech-language pathology services and ASHA will continue to advocate for additional coverage. ASHA also remains committed to advocating for full Medicare coverage of telepractice for audiologists and SLPs beyond the PHE.
Clinicians may be able to provide noncovered outpatient telepractice services to Medicare beneficiaries through a private pay arrangement.
Because audiologists and SLPs may now provide some services via telepractice to Medicare beneficiaries, they must be enrolled providers and submit claims for those covered services for reimbursement from Medicare. However, audiologists and SLPs may provide telepractice services to Medicare beneficiaries and enter into a private pay contract to receive reimbursement for services not currently covered via telepractice, with the patient's consent.
Medicare provides additional guidance for telepractice services in institutional settings.
Medicare has released additional guidance about telehealth services in institutional settings, such as skilled nursing facilities and hospital outpatient departments. However, guidelines still vary depending on the type of setting and whether services are paid under Medicare Part A or Part B. See ASHA's web page on Medicare coverage of telehealth services during COVID-19 for additional information on institutional billing.
Getting Started
Before starting telepractice, research payer policies and federal and state regulations during the PHE. Compliance is critical to help increase the chances coverage of audiology and speech-language pathology telepractice services remains beyond the PHE.
Most states and payers have developed temporary telepractice coverage and policies during the PHE. If they haven't, follow existing payer policies and state and federal regulations for telepractice. Remember, policies vary by state and payer, and may change during the PHE, so it's important to stay up-to-date. Always check with your employer, payer, and state licensing board for final guidance before engaging in telepractice. Here are key things you can do to prepare:
- Check whether your state covers telepractice by audiologists or SLPs.
- Learn general principles of coding and payment for telepractice services.
- Contact your payers directly for additional guidance regarding covered services via telepractice. Their policies may differ from state regulations.
- Follow best practice and legal requirements for telepractice, including using Health Insurance Portability and Accountability Act (HIPAA)-compliant software. Learn more through ASHA’s Practice Portal on telepractice, the Center for Connected Health Policy, and the American Telemedicine Association.
- Use ASHA's telepractice checklists to help keep track of key policies and regulations for each patient/client/student.
Expanded allowances for telepractice services during the PHE give audiologists and SLPs a chance to show federal and state legislators, payers, and patients the value of telepractice and to possibly secure permanent telepractice coverage. Compliance with state regulations, clinical best practice, payer policies, and established coding and billing guidelines is critical to help increase the chances telepractice coverage of audiology and speech-language pathology services remains beyond the PHE. (See also: How Can We Increase the Odds of Retaining Expanded Telepractice Coverage?)
Coding and Billing
Coding for telepractice services is similar to coding for in-person services, but check with each payer about the approved CPT code list and associated modifiers before you submit a claim.
You should report Current Procedural Terminology (CPT ® American Medical Association) codes and follow the same guidelines for appropriate billing of telepractice services as you would when providing in-person services. Payers typically also require a specific modifier or place of service code to distinguish telepractice services from in-person services. ASHA provides general guidance on coding for telepractice services but payer guidelines vary. Payers may also have a specific list of CPT codes approved for telepractice services. Always verify with the payer before initiating services.
E-visits, virtual check-ins, or other similar services do not replace CPT codes for full evaluation and treatment services.
Many payers, including Medicare, have implemented CPT or Healthcare Common Procedure Coding System (HCPCS) codes for communication technology-based services such as e-visits ( 98970-98972), remote image/video assessments (G2250), virtual check-ins (G2251), or telephone assessments (98966-98968). However, these generally do not replace full evaluation or treatment services reported using other CPT codes (e.g., 92507 for speech and language treatment, 92603 for cochlear implant programming). Think of these as brief check-ins or consultations to mitigate the need for an office visit or a full evaluation or treatment service.
Some payers may allow telepractice services provided over the phone (often called "audio-only" or “telephonic” services) if a patient doesn’t have the ability to participate over an audiovisual platform. This is different from the telephone assessments listed here and should probably be reported using the specific CPT codes for evaluation or treatment.
HIPAA Flexibilities
Federal laws and regulations may affect your ability to provide telepractice services.
Clinicians should be aware of federal laws and regulations related to privacy and security of patient and student records. For example, the Health Insurance Portability and Accountability Act (HIPAA) protects the transmission of health-related information and the Family Educational Rights and Privacy Act (FERPA) protects the privacy of student educational records. Although FERPA gives parents the right to consent to disclosure of personally identifiable information within educational records, school systems that receive Medicaid reimbursement for school-based services may also be bound by HIPAA requirements. See ASHA’s Practice Portal for additional information on telepractice privacy and security and COVID-19 considerations for schools for additional information on HIPAA and FERPA.
Note: CMS temporarily waived enforcement of HIPAA requirements during the federally declared national emergency related to COVID-19. Under some circumstances, including in private pay situations, clinicians may have increased flexibility to use a non-public facing communications platform that allows direct, real-time communication between patient and provider.
Loosened HIPAA regulations don’t apply across the board.
The Department of Health and Human Services (HHS) Office for Civil Rights (OCR) recently relaxed HIPAA enforcement of federal penalties, providing more flexibilities for health care providers to choose telepractice platforms. Although this will help audiologists and SLPs in many circumstances where they can provide telepractice services, other payer policies may still apply and can impact reimbursement of your services. Providers must ensure due diligence to payer policy at all times, but especially when providing a new service or a new delivery model, such as telepractice. Here are key considerations based on payer type:
- HIPAA flexibilities apply for self-pay patients who have no insurance or whose plans allow out-of-pocket payment arrangements.
- Commercial insurance plans may implement policies at their discretion, so check with and follow each payer’s policy.
- Although Medicaid is heavily guided by federal policy, each state Medicaid program will have some state-specific variation. Relaxation of HIPAA requirements may also apply to Medicaid, but check with your particular program directly.
- Medicare and TRICARE follow federal policy and have relaxed HIPAA requirements.
When Telepractice Isn't an Option
You may be able to work directly with payers to waive certain requirements for continuity of care.
You may determine that telepractice or other service delivery models aren’t an option for you or some of your patients/clients/students. In those cases, contact your payer or educational agency directly if you're concerned about violating an established education plan/plan of care by failing to provide treatment due to COVID-19. State agencies and payers generally allow missed sessions or a “hold” on care due to unforeseen circumstances, such as illness or inclement weather. They may also waive requirements related to disruption of care during emergencies. If you decide to place an individual on hold due to COVID-19, determine how long the hold should be, note the rationale for the hold in your documentation, and establish a plan to assess when to resume services.
ASHA provides additional guidance for audiologists and SLPs regarding in-person services and documentation of delays/gaps in service.
What ASHA Is Doing to Help (and What You Can Do Too!)
ASHA is now prioritizing advocacy urging Congress and payers to support permanent coverage of telepractice services.
As states and payers begin to consider telepractice beyond the public health emergency, ASHA is urging Congress, state Medicaid programs, and commercial insurers to permanently expand coverage of telepractice services to audiologists and SLPs. Clinicians can go to ASHA's Take Action site to ask your representatives to improve access to Medicare telepractice services beyond the COVID-19 pandemic. ASHA also encourages members to contact their local payers who have expanded services during the public health emergency and ask them to permanently cover telepractice services using ASHA's template letter for members [DOC] or state associations [DOC] and recommendations for telepractice coverage [PDF]. For additional advocacy support in your state, contact your state speech-language-hearing association.
In the meantime, it's critical for clinicians to use, code, and bill telepractice according to payer specifications to increase the chances of retaining telepractice services beyond the public health emergency. Here are some key considerations and a checklist [PDF] to guide clinicians on doing that.
ASHA continues to advocate for coverage of telepractice services across all major payers during the public health emergency.
Advocacy for comprehensive coverage and equitable reimbursement of audiology and speech-language pathology services—including telepractice—is a key health care priority of ASHA’s Public Policy Agenda. ASHA has also prioritized additional advocacy urging payers to support coverage of medically necessary audiology and speech-language pathology telepractice services on an emergency basis during this time. As a result, ASHA members have seen ongoing expansion of services across state Medicaid programs, commercial payers, and TRICARE. ASHA also successfully advocated for temporary access to certain audiology and speech-language pathology telepractice services under Medicare, and continues to advocate to add more audiology and speech-language pathology services to Medicare’s temporary telehealth services list.
Clinicians can also help with these efforts at a local level by contacting commercial insurers and state Medicaid programs. Use ASHA's Evidence Map on telepractice to find support for your discussions regarding the value of telepractice services. You can also use ASHA’s template letter for members [DOC] or state associations [DOC] and recommendations for telepractice coverage [PDF] to urge plans to expand audiology and speech-language pathology services during the public health emergency, if they haven't done so already.
For additional advocacy support in your state, contact your state speech-language-hearing association.
Questions?
Contact reimbursement@asha.org for additional information related to coding and payment for telepractice services. For clinical questions, audiologists can contact audiology@asha.org, SLPs in health care can contact healthservices@asha.org, and SLPs in schools can contact schools@asha.org. For questions about state laws and regulations, contact your ASHA state liaison [PDF].
