Navigating the healthcare landscape during this pandemic has felt a lot like navigating a high-speed, high-stakes obstacle course. Since March, regulations, laws, and payer guidelines have changed on an almost hourly basis, and physical therapists have had to gracefully maneuver around—and push back against—the many barriers to transitioning from in-person to virtual care. One of the biggest hurdles we faced was CMS’s reluctance to make PTs Medicare-authorized telehealth providers, which barred us from treating a large swathe of patients.
But after months of diligent, unified advocacy, CMS finally relented—and on April 30, 2020, the agency granted PTs, OTs, and SLPs (and eventually PTAs and OTAs) the temporary ability to provide and get paid for telehealth services. It was an amazing win for PT advocates, and it proved that our voices are loud enough to make a difference.
But, even though we’ve accomplished a lot, we haven’t crossed the finish line. In fact, it’s not even within our sight yet. The race is only halfway over, and the challenges we’re still facing could be even tougher to overcome than the ones we’ve already conquered. The pandemic has not ended—and neither has the urgent need for advocacy.
COVID-19 has fundamentally changed the healthcare landscape.
Prior to the pandemic, telehealth was not a priority for most physical therapy providers. It was definitely on our radar, but breaking down restrictive telehealth regulations took a backseat to more immediate concerns—like our industry’s ineffective branding, high patient copays, and woefully low reimbursement rates. In our 2019 State of Rehab Therapy survey, we asked rehab therapists to rate government and regulatory issues by impact, and telehealth ranked second to last—only beating out locum tenens restrictions.
Nowadays, telehealth is all anyone can talk about—for good reason. It’s one of the only ways we can continue providing care to our patients while also guaranteeing their safety and reducing our own risk of exposure. And the benefits of telehealth are widely recognized right now; there’s been a ton of telehealth regulatory change—at the federal, state, and individual payer level—in a very short amount of time.
Currently, almost every single state has specific legislation—whether temporary or long-standing—that explicitly allows PTs to provide telehealth, and a huge number of payers (both federal and commercial) are currently paying for remote physical therapy services. These were amazing wins for PTs—especially on the Medicare front—but most of these victories will be short-lived.
CMS, commercial payers, and even state governments are planning to let their telehealth expansions expire.
CMS, commercial payers, and state governments are not prepared to make the current telehealth guidelines permanent. In fact, many of these entities have explicitly stated that their telehealth expansions will expire.
United HealthCare, for instance, is currently planning to revoke PTs’ telehealth privileges on June 18, 2020. Anthem Connecticut will roll back the privileges it extended to PTs on June 15, 2020. CMS and a number of state governments are allowing PTs to keep these telehealth privileges “for the duration of the Public Health Emergency declaration,” and according to this CMS document, a public health emergency declaration automatically expires after 90 days unless it is extended by the Secretary of the Department of Health and Human Services (HHS).” The original public health emergency declaration was instituted on January 31, and would have expired April 30, 2020—but it was renewed on April 21. So, if allowed to run its course, the current declaration would expire on July 20. However, “The Secretary also has the freedom to “terminate the declaration whenever he determines that the [public health emergency] has ceased to exist.” Basically, the public health emergency could end at any time—even tomorrow.
What I’m getting at is that, while it’s been inspiring to watch our industry adapt to current events, the wins that we’ve secured—our current telehealth privileges—are shaky at best.
Returning to the status quo would be a disservice to patients.
I’d be remiss not to highlight how much telehealth has helped our patients. It’s keeping them in their homes and helping them stay safe—but it’s also allowing them to get the care they need to live fully functional lives.
Because virtual physical therapy was so uncommon prior to COVID-19, only a small number of studies have investigated the relationship between telehealth physical therapy and patient outcomes. However, those studies suggest that there’s a neutral relationship between outcomes and telehealth—meaning that virtual care is equally as effective as in-person care.
Now, telehealth will never fully replace in-person care (nor do I think that it should), but our patients could seriously benefit from having permanent access to this treatment option. It allows us to better assist patients who struggle with either in-city mobility (e.g., disabled or elderly patients) or inter-city mobility (e.g., patients who live in rural communities). It also bolsters our ability to offer more care to those who live in Health Professional Shortage Areas (HPSAs). Returning to the status quo when we just opened the door to better care accessibility would be a huge disservice to our patients. And that’s especially true considering that—even though the country is beginning to reopen—experts are predicting a large resurgence of COVID-19 infections in the fall. That could result in another lockdown, more social distancing, and a need for therapists to once again treat their patients remotely. But how are we supposed to care for those patients if our telehealth privileges have already expired? Do we really want to fight this fight again—and lose precious time, revenue, and patient care continuity in the process?
Many rehab therapy clinics will need telehealth to stay financially viable.
Speaking of revenue: Despite the federal government’s best attempt to stabilize the economy through gargantuan stimulus packages, the country’s overall financial state is still tenuous—and PT clinics have felt the financial blow of the pandemic just as much as the next business. Telehealth may not exactly pad the coffers, but it’s helping clinics keep their doors open—for now.
Additionally, businesses are finding that consumers are slow to return to their normal lives; people are still scared. So, even though we’re finally opening back up—and elective surgeries are now allowed in many states—clinics shouldn’t expect a sea of patients to come flooding through the doors. It’ll probably take some time for most practices to climb back up to their pre-COVID-19 patient volume. This will become an even bigger problem when clinics have to start paying back the emergency loans and advance Medicare payments they sought out to help soften the blow of the pandemic’s initial financial hit. And without telehealth as an additional revenue source—well, let’s just say that’ll make a tough situation even tougher.
And when clinics close their doors, patients are hurt, too. They’re left with fewer options and less access to necessary care.
We must reignite our telehealth advocacy efforts—today.
If we want to keep telehealth in our back pocket, if we want to better serve and protect our patients while preserving our financial health, then we need to rekindle our telehealth advocacy efforts—today. It took a lot of work to get us where we are, but we don’t have time to rest. The race is not over! Our telehealth privileges are not permanent, and we cannot truly claim victory until they are.
We have major momentum right now, and that puts us at a huge advantage. It will be far easier to convince payers and government bodies to permanently adopt the current measures than it will be to start from scratch several years down the line. This is our time to act!
We must advocate for telehealth on multiple fronts.
The APTA is currently supporting and advocating for passage of the CONNECT for Health Act, a piece of legislation that would “ease restrictions on telehealth coverage under the Medicare program.” (You and your patients can support this legislation here.) That is a wonderful first step, because it would permanently authorize rehab therapists as telehealth providers at the federal payer level (e.g., with Medicare). But, it’s only a first step.
As we all know, states and commercial payers don’t have to—and often don’t—adopt federal policy. If your state doesn’t keep telehealth under the PT scope of practice, then it won’t matter if you can provide telehealth to Medicare beneficiaries. You legally will not be able to practice telehealth—full stop. That’s why it’s mission critical that we advocate for not only federal changes, but also state and commercial payer changes. This may seem like a herculean task, but it’s one that we can’t afford not to tackle. We must pick up the gauntlet and get ready to fight for our patients and our industry.
There’s more at stake than telehealth privileges.
Our advocacy efforts cannot stop at telehealth. We must take action on another high-priority advocacy issue: Medicare’s plan to cut PT payments by an estimated 8% beginning January 2021. It is imperative that we push to repeal these finalized cuts. We are not alone in this fight; more than three dozen other provider types are also affected by these cuts—but we must band together to make our voices heard. PTs have endured unprecedented financial hardship in the wake of COVID-19, and a sweeping cut of this nature could cripple the industry. So, contact Congress. Send a letter to your representatives (here’s a free template); send a letter to your senators; send a letter to CMS Administrator Seema Verma. We must make our voices heard—and we can only do that together.
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The race may only be halfway done—and we may have a ways to go before we break the tape. But I genuinely believe that if we band together, we can do great things. We CAN secure permanent access to telehealth. We CAN convince CMS to reverse those 8% cuts. We CAN survive this pandemic. And we’re going to do it together. Are you ready?
