ArizOTA understands the importance of providing OT practitioners, students, and community stakeholders with the latest information and resources regarding the provision of occupational therapy services in Arizona during the COVID-19 pandemic.
Please see below for the current status of telehealth regulations and reimbursement in Arizona; news about active state legislation relating to OT and telehealth; and other timely updates. We will share additional information as it becomes available, so check back frequently.
Last Updated: 1/6/2021
On March 25, 2020, Governor Ducey issued an Executive Order authorizing occupational therapy practitioners to provide services via telehealth beginning March 25, 2020 and lasting through the end of the declared Public Health Emergency.
The Executive Order requires health care insurance companies to expand telemedicine coverage for all services that would normally be covered for an in-person visit, and prevents insurers from charging more for a telemedicine visit than they would for an in-person visit. In addition, the order:
- Requires all Medicaid plans in the State of Arizona to cover all health care services that are covered benefits to be accessible by telemedicine to AHCCCS members, while prohibiting those plans from discounting rates for services provided via telemedicine;
- Includes all electronic means of delivering telehealth including telephone and video calls;
- Ensures that a patient’s home is considered an approved location to receive telemedicine services.
Board staff received clarification on [Executive Order 2020-15 Expansion of Telemedicine] from the Governor’s office on 3/26/2020. This order includes occupational therapy assistants, as item 6 states telehealth services may be provided by “any Arizona licensed healthcare provider type including but not limited to…”. Item 9 means that the practice of occupational therapy is the same as it was before telemedicine was allowed. Any treatments you were not authorized to provide before telemedicine are still not authorized.
For information regarding the practice of telemedicine, please refer to Arizona Revised Statutes Title 36: Chapter 36.
Please do not contact Board members, as they are not able to speak for the Board outside of Board meetings. Questions can be emailed to firstname.lastname@example.org, or you can call Karen Whiteford at (602) 284-7433.
What happens with telehealth after the COVID-19 public health emergency?
Following a meeting with our lobbyist on May 19, 2020, ArizOTA’s Legislative Affairs Committee provided the following update:
There is broad-based support for continuing telehealth after the Public Health Emergency. This support includes healthcare organizations, healthcare provider groups, business and community support, along with government stakeholders. The tone is positive, but there are no specifics. A related angle is liability protection/reform proposals in the broader discussion. The legislative schedule and calendar remains uncertain. Therefore it is tough to predict actual details, dates, and any coming calls to action. 2020 is also an election year which may play into the decisions and actions in some way. The Legislative Affairs Committee continues to work with our lobbyist to monitor the changing situation.
DDD: In a COVID-19 update email sent on March 17, the Division of Developmental Disabilities announced it is authorizing the use of telehealth to “deliver Speech Therapy and Occupational Therapy services as outlined in AHCCCS Policy 320-I.”
AHCCCS: Normally, occupational therapy is not currently a covered service under AHCCCS telehealth regulations. However, in a conference call held on March 20, 2020 with 3,000 healthcare providers, AHCCCS committed to reimbursing occupational therapy services provided via telehealth during the COVID-19 emergency. OT practitioners can use the same OT CPT® codes but must add a telehealth modifier and specify location.
On December 18, 2020, AHCCCS announced a Telehealth COVID-19 Policy Date Extension stating that the AHCCCS telehealth COVID-19 policy coverage flexibilities have been extended through 9/30/2021. If the COVID-19 pandemic continues beyond 9/30/21, AHCCCS will re-evaluate this end-date. Please visit the AHCCCS COVID-19 FAQs for additional COVID related information, at https://azahcccs.gov/AHCCCS/
Commercial Health Insurance: Visit AOTA’s web page, Commercial Insurance Plans Adding Coverage for OT Telehealth Services in Response to COVID-19, for the latest updates about commercial health insurance reimbursement for telehealth.
TRICARE: According to its website, “TRICARE covers the use of interactive audio/video technology to provide clinical consultations and office visits when appropriate and medically necessary (appropriate, reasonable, and adequate for [a patient’s] condition.” (TRICARE Policy Manual, Chapter 7, Section 22.1). It is recommend that practitioners verify benefits prior to initiating OT services via telemedicine.
Medicare: On April 30, 2020, the Centers for Medicare & Medicaid Services (CMS) announced that occupational therapists can perform telehealth services for Medicare beneficiaries as part of a new blanket waiver. The waiver is retroactive to March 1, 2020 and is effective throughout the public health emergency. Telehealth services can be billed using the list of telehealth approved CPT® codes that CMS issued on March 30, 2020. See AOTA’s update for full details.
On December 31, 2020, CMS provided the 2021 Annual Update to the Therapy Code List.
Workers’ Compensation: On April 14, 2020, Governor Ducey signed Executive Order 2020-29, which expands telemedicine options and requires workers’ compensation insurance plans regulated by the State to provide coverage for telemedicine services. It will allow all electronic means of delivering telehealth, including telephone and video calls.
ArizOTA represents occupational therapy practitioners, students, and stakeholders and does not support any specific vendor or company. However, WebPT has compiled useful information and resources regarding telehealth reimbursement. Considering the urgency and fluidity of the COVID-19 crisis, we are including this link as one more source of information for your use if you find it helpful. Read here.
The Executive Order allowing the provision of OT through telehealth is in effect only until the end of the declared Public Health Emergency. We still need your support to ensure our telehealth bill gets passed so we can practice via telehealth well beyond the COVID-19 emergency.
Introduced prior to the COVID-19 pandemic but becoming more timely by the day, Arizona House Bill 2536 is an inter-professional telemedicine bill aimed at recognizing occupational therapy practitioners (as well as PT, SLP, and ATC practitioners) as telehealth providers in the state of Arizona. This bill would recognize OTs and OTAs as telehealth providers and would be a first step in securing reimbursement for telehealth services by insurance providers, including AHCCCS, Medicare, and commercial insurances.
Currently, the bill has passed through the Arizona House of Representatives and is in the Arizona State Senate awaiting a vote.
ArizOTA’s advocacy has helped get the bill to this point, and we now need your help to ensure it is passed! Find your state legislators and contact your Arizona state senator today and let them know the importance of recognizing OTs/OTAs as telemedicine providers.
Coronavirus Resources from AOTA
AOTA is working to provide ongoing resources related to occupational therapy in the era of Coronavirus Disease (COVID-19), including FAQs for practitioners, students, and educators.
AOTA is also hosting a series of FREE virtual CE programs to equip occupational therapy practitioners, educators, and students to navigate through the evolving coronavirus pandemic. This series is free for AOTA members and non-members, and is available live and recorded. Earn from 1 to 1.5 contact hours per session.
State Licensure News from ABOTE
Governor Ducey signed Executive Order 2020-17, Continuity of Work, on March 26. This order helps licensed professionals in the state stay licensed and defers certain requirements for six months.
On their website, ABOTE states it is complying with this executive order by:
- Giving six-month license extensions to those who cannot complete their continuing education in time because of COVID-19
- Issuing six-month provisional licenses to new graduates that cannot take the NBCOT exam because the testing centers are closed
- Issuing six-month provisional licenses to those applying for a new license who cannot obtain fingerprints
NBCOT Testing Updates
On March 17, NBCOT received information that its testing contractor, Prometric, is closing all testing centers in the United States and Canada per recent federal guidance from the Centers for Disease Control and Prevention (CDC). At this time, Prometric is stating the closures will last 30 days, but reopening of test centers will be dependent on circumstances that are changing daily.
For Arizona applicants waiting to test, ABOTE has recommended you apply for a Limited License.
NBCOT Recertification Updates
- All certificants due to renew in 2020 will retain their active OTR® or COTA® certification until May 31, 2020.
- This gives you two additional months to obtain the units required for certification renewal.
- If you do not renew by May 31, 2020, your certification status will change to Expired on June 1.
- If you renew your certification after May 31, 2020, you will be charged the late fee.
Free COVID-19 Antibody Testing
The state of Arizona and the University of Arizona are providing free COVID-19 antibody testing to healthcare workers and first responders at more than 30 testing sites across the state. All OT practitioners licensed in Arizona are eligible to be tested.
CMS Allows OTs to Open Medicare Home Health Cases
ACRM Pandemic Webinar Series
The American Congress of Rehabilitation Medicine will be hosting live sessions with experts from the telemedicine industry to provide clear and up-to-date information regarding telemedicine and remote monitoring in the field of physical medicine and rehabilitation during the COVID-19 crisis. The FREE webinars will also be available as recordings.
NAHC Resources for Home Health
The National Association for Home Care & Hospice is providing guidance applicable to home health OT practitioners on its Coronavirus Resources for Home Care & Hospice web page.
CARES Act Analysis
March 28: ArizOTA’s Legislative Affairs Committee member Veda Collmer explains the small business lending opportunities and expanded unemployment benefits available to eligible OT practices.
OT Small Business Owners: Information and Resources for Applying for Disaster Loan Programs
April 24: ArizOTA’s Legislative Affairs Committee member Veda Collmer explains the two types of loans available for small businesses who are struggling due to the COVID-19 pandemic: the Paycheck Protection Program (PPP) and Economic Injury Disaster Loans (EIDL).