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    Telehealth Update for NH OT Practitioners

    April 30, 2020 Update:

    “The Centers for Medicare & Medicaid Services (CMS) announced the long awaited news today, April 30th, that occupational therapists, physical therapists, and speech language pathologists can now perform telehealth services for Medicare beneficiaries.

    New Wavier Language:

    Eligible Practitioners. Pursuant to authority granted under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) that broadens the waiver authority under section 1135 of the Social Security Act, the Secretary has authorized additional telehealth waivers. CMS is waiving the requirements of section 1834(m)(4)(E) of the Act and 42 CFR § 410.78 (b)(2) which specify the types of practitioners that may bill for their services when furnished as Medicare telehealth services from the distant site. The waiver of these requirements expands the types of health care professionals that can furnish distant site telehealth services to include all those that are eligible to bill Medicare for their professional services. This allows health care professionals who were previously ineligible to furnish and bill for Medicare telehealth services, including physical therapists, occupational therapists, speech language pathologists, and others, to receive payment for Medicare telehealth services.”

    AOTA Medicare Telehealth Success

    A listing of services payable under the Medicare Physician Fee Schedule when furnished via telehealth can be found here:


    April 23, 2020 Update:

    Governor Sununu, in his Emergency Order dated 3/23/20, ordered the expansion of telehealth coverage to include many different professions, including Occupational Therapy. This allows us to bill our CPT codes for services rendered in the state of NH. In April 2020, the Governor also expanded services to ease restrictions on out of state practitioners. OT's are advised to do their due diligence and follow applicable laws when practicing telehealth. NH medicaid has been ordered and has complied with said order and now covers telehealth services, including those provided by Occupational Therapists. Many private insurances are covering OT CPT codes but this can vary by policy and therapists and patients are strongly encouraged to check their coverage. Visit limits and co-pays will apply. These visits need to be coded appropriately as telehealth visits with the correct modifiers. Check with your billing department or software or service to ensure correct billing.  Consent can be obtained verbally and should be documented. Also, please consider HIPAA concerns with privacy when choosing a telehealth platform. Of note, Medicare DOES NOT cover telehealth services provided by OT, PT or ST despite including our CPT codes in covered codes. Please refer to the state FAQ for more information:


    March 20, 2020:

    Dear Members, 

    Many of us are struggling with the challenges of the COVID-19 virus. We are trying to find ways to provide treatment and education to our clients and students. Recent developments with greater freedom for providing telehealth presents new opportunity and challenges for healthcare providers. NHOTA would like to provide you with resources that you can use to navigate telehealth to provide quality care that is ethical, appropriate and helpful.  

    Reminder: you can only perform telehealth services to people in the state(s) you are licensed in. 

    CMS has relaxed the coverage guidelines for telehealth coverage.  The following link is a tip sheet and includes billing codes therapists can use.  One caveat: there must be a face-to-face encounter with you prior to telehealth, so they must be an established patient. 



    CMS has also made recommendations for privacy concerns when providing telehealth:

    They recommend the following platforms from vendors that claim HIPAA compliance: 

    • Skype for business
    • Updox
    • VSee
    • Zoom for Healthcare
    • Google G Suite Hangouts Meet


    Governor Sununu enacted an emergency order that initially limited telehealth to physician-type providers, but he expanded that coverage on March 18th to include providers licensed by the Office of Allied Health Professionals. That would expand coverage to OTs within the state of NH. Click here to download the document

    AOTA has provided an FAQ that is accessible to non-members: However, members have more access and more ability to connect with other OTs for ideas and guidance in telehealth opportunities. 

    Now, more than ever, we need to meet this challenge and expand our practice and comfort zones.  When this crisis is over, the option for telehealth will once again be restricted to rural areas and physicians. We need to look forward and work on a legislative agenda in our state that will allow occupational therapy and allied health to have easy access to an effective method of delivering critical services and be able to bill for those quality services.

    Telehealth is evidence-based and an emerging field. Make sure NHOTA hears your voice on how you will use telehealth to expand your practice and reach.  When this crisis is over, help NHOTA push this legislatively and be a strong voice in NH demonstrating the value of occupational therapy.