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The following questions and answers were from the Monitor Mondays broadcast on April 7, 2020 and the answers reflected the current status of guidance at the time of the broadcast. Please be aware that this information could change without notice. To stay current on the latest regulatory news and information, register to listen to Monitor Mondays. To listen to the Monitor Mondays podcast from April 7th, 2020.



Have you heard if the Medicare Prior-Authorization Program for Outpatient Department will be delayed due to COVID?.

Reference https://www.cms.gov/research-statistics-data-systems/medicare-fee-service-compliance-programs/prior-authorization-initiatives/prior-authorization-certain-hospital-outpatient-department-opd-services

Can you please repeat the website mentioned by Dr Hirsch about clinical recommendations?

 Reference https://emcrit.org/emcrit/avoiding-intubation-and-initial-ventilation-of-covid19-patients/

Do you think that the IPPS Proposed Rule will be released at the end of the month?

Wow, that is something that I doubt anyone has thought about. I am going to guess “yes” since they have been releasing other no-COVID things.

David – for those therapy companies that have Management Services Arrangements already in place with physician offices, and are ALREADY billing incident-to, is not a problem…..

It isn’t crystal clear.  Someone could argue that PTs/OTs/SLPs can’t do telehealth at all.  I think I would take the risk, but it isn’t crystal clear incident to works. 

Does an NP need a physician to co-sign if they cover in the ER in a critical access hospital?

If it was required before, it still is.

What about Hospital-based Pt/OT therapy services?

The same question exists, but the argument that you can do it as “incident to” is weaker, since incident to isn’t allowed in the hospital setting.  Great question.  We don’t really know the answer. 

Does the NP need a physician co-signature if covering in the ER at a critical access hospital ER.

If it was required before, it still is.

The new coding guidelines are a little confusing when assigning PDX for Covid-19 and Sepsis.
I have seen interpretations that suggest assigning COVID-19 (U07.1) as PDX and Sepsis as a secondary since it supersedes coding guidelines. U07.1 is only a secondary code for neonates and OB.
Another interpretation is that the sepsis guidelines should be followed, so if POA, sepsis should be principal diagnosis.

The Guidelines state
For a COVD-19 infection that progresses to sepsis, see section I.C.1.d, Sepsis, Severe Sepsis, and Septic Shock.

Ref: ICD Official Guidelines, April 1, 2020, through September, 30, 2020

For a COVD-19 infection that progresses to sepsis, see section I.C.1.d, Sepsis, Severe Sepsis, and Septic Shock.


Please reference this ICD10monitor article written by Erica Remer, MD titled ‘We now Have a Code for COVID-19; Here’s How to use it Correctly’

PT/ST/OT can use evisit codes. They dont qualify as Telehealth but if they meet the guidelines they can bill those services with G0261-G0263

This is true but they are limited to one a week and valued quite low

Would the Hospital be able to charge the Originating Fee when the Consultation is done from a distant site?

If you did in the past, do it now.

Can you post the link to the statute that lists who is eligible to perform telehealth services? Tx!



Page 6 here lists eligible practitioners- https://go.cms.gov/mln-telehealth-services-icn901705

The codes are here: https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes

Can PT provide therapy services to patients at home now? Patients would not technically be defined as home bound.

If the therapist went to the home I suspect it would be as part of a home health episode of care and the homebound rule would need to be met.  But if they have COVID, they are homebound.


Chuck Buck

Chuck Buck is the publisher of RACmonitor and is the program host and executive producer of Monitor Monday.

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