Practice Management Updates

Telehealth and COVID-19
(May 14, 2020)

ASHT is providing the following list of resources to assist members with implementing telehealth services. Resources include webinars, FAQs, coding and billing guidelines and reimbursement information.

American Occupational Therapy Association

American Physical Therapy Association

Centers for Medicare and Medicaid Services

American Medical Association

Durable Medical Equipment, Prosthetics, Orthotics and Supplies (DMEPOS): CMS Flexibilities to Fight COVID-19 Update
(April 7, 2020)

Submitted by: Angela M. Stephens, DHS, OTR/L, CHT

In response to the COVID-19 pandemic, there are several temporary changes across the entire U.S. healthcare system.  These changes will be immediate and will be in place during the emergency declaration time period. In summary, the goals for this action are:

  • Ensure local hospitals and health systems have the capacity to handle the patient volume due to COVID-19, temporary expansion sites.
  • Remove barriers for physicians, nurses, and other clinicians to be readily hired to meet the healthcare demand
  • Increase access to telehealth in Medicare
  • Expand in-place testing
  • Patients Over Paperwork, to allow focus on patient care for Medicare and Medicaid beneficiaries that may be affected by COVID-19

Patients Over Paperwork

Patients Over Paperwork will allow DME Medicare Administrative Contractors the flexibility to waive replacement requirements for DMEPOS.  However, the claim must include a narrative description from the DMEPOS supplier as to why a replacement was warranted.  The DMEPOS Medicare Prior Authorization program has been paused for certain items.  CMS is not requiring accreditation for newly enrolled DMEPOS providers, and the expiring supplier accreditation is extended for 90-days.  The “proof of delivery” signature requirement has been waived by CMS for both Part B drugs and DME.  Documentation should be placed in the medical record stating date of delivery and that the signature could not be obtained.  In addition, CMS has expanded the Accelerated and Advance Payment Program.  Medicare providers should submit the request to the appropriate Medicare Administrative Contractor (MAC).  Each MAC will then review the request and issue payments within 7 calendar days of receipt dependent upon the provider has met the required qualifications.  A fact sheet has been developed by CMS and can be viewed on this link:

Medicare Appeals in Fee For Service (FFS), Medicare Advantage (MA), and Part D

CMS is allowing MACs and Qualified Independent Contractors in certain FFS programs, MA, and Part D plans to allow extensions to file appeals and to process appeals with the flexibilities that are available if good cause requirements are met.  In addition, some FFS programs are permitted to waive requirements for timeline requests of additional information to adjudicate appeals.  Medicare Advantage plans may extend time frames by 14 calendar days to adjudicate determinations and reconsiderations for medical items and services based upon certain requirements.  For more detailed information please review this link: