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: 3/26/2020 at 8:45 p.m.
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.
Arizona Board of Occupational Therapy Examiners (ABOTE) Statement – Updated 3/25/2020 at 9:33 a.m.:
GOVERNOR DUCEY ISSUED EXECUTIVE ORDER 2020-15 EXPANSION OF TELEMEDICINE
Update 3/25/2020 9:33 a.m.: Governor Ducey issued Executive Order 2020-15 which expands telemedicine to include occupational therapists.
The Board is not able to interpret the language of the order or give legal advice. However, the order does say telehealth services may be provided by “any Arizona licensed healthcare provider type including, but not limited to….”
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 email@example.com, or you can call Karen Whiteford at (602) 284-7433.
A HUGE thank you to ABOTE, ArizOTA’s lobbyists, everyone who sent a letter to Governor Ducey, and the Governor himself for making this happen!
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 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. (AHCCCS FAQs Regarding Coronavirus Disease 2019 (COVID-19) ***Please note that OT CPT codes are not currently listed on AHCCCS’s telehealth code list on this linked webpage. However, per the March 20 conference call, OT services via telehealth will be reimbursed.)
Commercial Health Insurance: Per AOTA:
…with private/commercial payers, coverage for OT services provided via telehealth will vary by plan. Many plans are electing to waive cost-sharing (co-payments, deductibles, and co-insurance) or otherwise expanding access for telehealth services—for example, CVS/Aetna is waiving co-payments for telemedicine visits for any reason under certain circumstances, and Blue Cross and Blue Shield is encouraging its member plans to provided expanded access to telehealth services. Some plans are implementing this just for services provided to individuals diagnosed with COVID-19, but some are doing so for all currently covered telehealth services, no matter the diagnosis. Whether OT is included depends in part on whether the state scope of practice allows for OT to be provided via telehealth and also on the plan policies and benefits structure. Practitioners are encouraged to contact the plans directly to determine the plans’ current policy and approach to the provision of OT telehealth services.
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: CMS does not currently recognize occupational therapists as telehealth providers, even under the expanded telehealth 1135 waiver. However, under Medicare Part B will reimburse for E-Visits, which is “a communication between a patient and their provider through an online patient portal.” From the CMS Telemedicine Fact Sheet:
E-VISITS: In all types of locations including the patient’s home, and in all areas (not just rural), established Medicare patients may have non-face-to-face patient-initiated communications with their doctors without going to the doctor’s office by using online patient portals. These services can only be reported when the billing practice has an established relationship with the patient. For these E-Visits, the patient must generate the initial inquiry and communications can occur over a 7-day period. The services may be billed using CPT codes 99421-99423 and HCPCS codes G2061-G2063, as applicable. The patient must verbally consent to receive virtual check-in services. The Medicare coinsurance and deductible would apply to these services.
Medicare Part B also pays for E-visits or patient-initiated online evaluation and management conducted via a patient portal. …
Clinicians who may not independently bill for evaluation and management visits (for example – physical therapists, occupational therapists, speech language pathologists, clinical psychologists) can also provide these e-visits and bill the following codes:
- G2061: Qualified non-physician healthcare professional online assessment and management, for an established patient, for up to seven days, cumulative time during the 7 days; 5–10 minutes
- G2062: Qualified non-physician healthcare professional online assessment and management service, for an established patient, for up to seven days, cumulative time during the 7 days; 11–20 minutes
- G2063: Qualified non-physician qualified healthcare professional assessment and management service, for an established patient, for up to seven days, cumulative time during the 7 days; 21 or more minutes.
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 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.
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.
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 take place every Tuesday, Thursday, and Friday at 1 p.m. EDT from Tuesday, March 24 to Thursday, April 9.