Important Update from the Ohio OTPTAT Licensure Board Regarding OTA Licensure Renewal.

For the upcoming 2020 renewal:

• Expiration date for current OTA licenses has been extended through December 1^st, 2020
• OTAs are encouraged to renew by June 30^th if ready to renew
• 20 units of CE continue to be needed by June 30^th, 2020 (completed between July 1, 2018-June 30, 2020, including one hour of ethics, jurisprudence, or cultural competence)

Please see the full memo on the front page of the board website here.

Covid-19 - What OT Practitioners Need to Know

The past month has given occupational therapy practitioners and students an unprecedented level of challenge, both personal and professional. We have attempted to gather as many helpful resources as possible in one place to assist you as you navigate these uncertain times. Please know guidelines and recommendations are fluid and changing almost daily, so we are doing our very best to continue to update these as fast as they are changed.

Continuing Education and OOTA Meetings

We have moved to virtual meetings for conducting all necessary board business in an effort to ensure we are following social distancing recommendations. At present, all CE workshops or district meetings scheduled for March and April have been postponed until further notice. We are working towards moving any CE offerings that can be held virtually via webinar to that format to avoid rescheduling but will keep you informed as things develop. May events will be determined in the coming weeks.

Ohio Department of Health (ODH) Guidance

Please follow these links for recommendations for health care professionals and a list of public health and Governor DeWine executive orders specifically related to Covid-19. Recommendations and information for the general public can be found here.

Centers for Disease Control (CDC) Guidance

Please follow these links for recommendations for health care professionals and health care facilities specifically related to Covid-19. Recommendations for the general public can be found here.

Guidance for Acute Care

Please follow this link from the Ohio Hospital Association with recommendations for health care professionals specifically related to Covid-19. 

Ohio Dept. of Job and Family Services Covid-19-Related Unemployment FAQ

Please follow this link for resources related to unemployment insurance benefits for those employees with job loss due to Covid-19 illness or quarantine. 

Telehealth - Medicaid

OOTA worked this week with the Ohio Department of Medicaid (ODM) in collaboration with the OTPTAT Licensure Board to ensure that occupational therapy practitioners would be included in the emergency declaration by Governor DeWine to allow for telehealth services in Ohio. This emergency order was issued 3/19/2020 and the final rule was filed by ODM on 3/20/2020. 

Ohio Department of Medicaid Telehealth Rules: Frequently Asked Questions can be found here.

OOTA Members can find more telehealth resources here.

Telehealth is defined as follows in the rule:

New and established patients may be provided services through telehealth per this rule. No initial face-to-face visit is necessary to initiate services through telehealth. Please note this definition includes both synchronous and asynchronous activities.

This appendix includes CPT codes that can be billed under telehealth under this rule. Specific codes for therapy are listed below:

E-Visits - Medicare

While occupational therapy practitioners are still excluded from provision of telehealth services under Medicare, CMS has allowed for expanded provision of “e-visits” under the March 17^th federal changes in response to Covid-19.

Good guidance related to this change is provided on the AOTA website and is copied below. Please note that HIPAA-compliant communications will not be required or enforced during this time so that access will be able to continue as seamlessly as possible. 

The CPT 2020 Coding Manual included new codes for qualified nonphysician health care professional online digital evaluation and management services. In the 2020 Medicare Physician Fee Schedule (MPFS) final rule, the CMS did not accept these codes and created their own G codes for qualified nonphysician health care professional online assessment (e-visits).

It was unclear when the fee schedule was released if CMS intended for occupational therapists to be allowed to use these codes. With today’s telehealth expansion during the COVID-19 outbreak, CMS clarified that occupational therapists can bill for these e-visits.

The G codes to use for Medicare are:

AOTA E-Visit Coding Guidance

In order to provide these e-visit services, the client must be established with the practice, and the client must initiate contact. Contact is usually made electronically through a patient portal, but it can also be made through a phone call or an email. Billable time starts when the practitioner reviews the inquiry, and includes any time over the next 7 day period assessing the problem, creating a management plan, ordering tests, and digitally communicating with the client.

However, according to American Medical Association coding guidance, if the client’s inquiry is related to a condition that was treated in-person in the office within the past 7 days, the online service is not billable. Also, if the client comes into the office within 7 days of the inquiry related to the same condition, the online service is not billable.

Temporary Lifting of HIPAA Technology Compliance Only During Public Health Emergency

It should be noted that as part of the March 17 announcement, CMS indicated that the Department of Health and Human Services, Office of Civil Rights (HHS OCR), the office responsible for enforcing the Health Insurance Portability and Accountability (HIPAA) Act, will exercise enforcement discretion during the COVID-19 public health emergency (PHE). This means that if providers use technology during the PHE that is not fully compliant with HIPAA, HHS OOCR will not impose penalties on providers. After the PHE is lifted, providers must conform by using HIPAA-compliant technology.

AOTA Advocacy with Congress for Access to Telehealth Services

AOTA has been advocating with Congress to increase access to occupational therapy services under Medicare, and those efforts are more important than ever right now. To write to your members of Congress about expanding access to occupational therapy services under Medicare, please visit our Legislative Action Center. Additional information on COVID-19 resources, including telehealth services, can be found at www.aota.org/coronavirus.  

Guidance for Skilled Nursing/Long Term Care

• Medicare has issued a waiver of the 3-day qualifying stay for skilled nursing stays for beneficiaries. Patients can be admitted without having had a qualifying stay if they are deemed to need skilled nursing care, or if they are dislocated from the hospital due to other patients requiring more acute care. 
• Medicare has also issued a waiver for replacement of durable medical equipment that has been lost, destroyed, damaged, or otherwise rendered unusable during this timeframe. Where Durable Medical Equipment Prosthetics, Orthotics, and Supplies (DMEPOS) is lost, destroyed, irreparably damaged, or otherwise rendered unusable, contractors have the flexibility to waive replacements requirements such that the face-to-face requirement, a new physician’s order, and new medical necessity documentation are not required. Suppliers must still include a narrative description on the claim explaining the reason why the equipment must be replaced and are reminded to maintain documentation indicating that the DMEPOS was lost, destroyed, irreparably damaged or otherwise rendered unusable or unavailable as a result of the emergency.
• The American Health Care Association (AHCA) and the National Center for Assisted Living (NCAL) have issued a joint guidance statement regarding use of OT, PT, and SLP personnel in LTC facilities during the COVID-19 Pandemic. While your employer will already have procedures in place, these general recommendations have been made via the statement:

1. Review the care plan and its goals and discuss with the resident if the current rehabilitation plan needs to continue or be modified. 
   1. Some therapy plans of care can be suspended or modified focusing on essential needs, which may vary depending on the current situation in the center or with individual residents. 
   2. This should evaluate which, if any, specialized rehabilitative services are essential to meet the resident’s health care needs at this time, and which should be deferred. NOTE: If COVID-19 begins to spread in your facility and staffing levels drop, therapy professionals in a LTC   facility should anticipate being asked to provide additional public health support activities within the center and therapy services may need to be suspended in order to meet other residents’ basic needs. 
2. Group and concurrent therapy should be discontinued, if part of the care plan. 
3. Consider delivering care in individual resident rooms rather than in therapy gyms, and individualized one-on-one care should be provided in a manner to maintain social distancing as practicable. 
4. Extra care should be taken following CDC guidance when cleaning therapy equipment between uses. 
5. Non-essential personnel, especially non-direct care staff (e.g., billing) should continue their work as feasible through remote communication, such as via video chat or phone calls. There may be situations where therapy clinicians furnish care in more than one LTC facility during a single day. 
6. Movement of staff between buildings is suspected to be one mechanism of Page 2 of 2 March 19, 2020 COVID-19 spread. As such, if COVID-19 is discovered in a building, therapists should consider limiting their movement to other buildings and self-monitor for fever or respiratory symptoms.

AOTA has additional resources links to CMS Guidance documents available here.

Guidance for Early Intervention & School-Based Practice

Our contacts at the Ohio Department of Education are encouraging us to utilize telepractice to meet US Department of Education recommendations for continued services. Please refer to this update from the US Department of Education.

OOTA is deferring to the AOTA FAQ page for more information on Special Education, Early Intervention, and 504 Service provision here.

Q. What are my responsibilities to provide occupational therapy services to students under the IDEA and Section 504 if my school closes?

According to the Department of Education’s guidance, if a school closes and does not provide any educational services to the general student population, then the school is not required to provide services to students with disabilities. After the school reopens, the IEP or 504 team should make an individual determination about whether the student would need additional or compensatory services. 

If a school closes but continues to provide educational opportunities to students, the school is required to ensure students with disabilities also have equal access to the same opportunities. Also, to the greatest extent possible, each student with a disability should be provided the special education and related services identified in the IEP or 504.

Q. If my school is required to provide services, how should occupational therapy services be provided?

You should work with your school and students’ IEP teams to determine which of the different methods of service provision are the most appropriate during a school closure. Options include online and virtual instruction, instructional calls and activities, services provided in an alternative location, or possibly services provided in the student’s home. The ability of occupational therapy services to be provided through remote options/telehealth varies by state, as does the ability of these services to be billed under Medicaid and under private insurance. Some state occupational therapy regulatory agencies also have enacted practice standards governing the provision of OT services via telehealth. For a state-by-state chart of the telehealth laws, AOTA’s telehealth position paper, and other considerations, please visit AOTA’s Telehealth Resources page.

Q. Do I still need to provide services if a child with an IEP is absent for an extended period of time because they are infected with COVID-19 while the school remains open?

Yes. Generally, when a student is absent for more than 10 consecutive school days they would be classified as needing homebound instruction. The IEP team should meet to determine whether the child is available for instruction, could benefit from homebound services or virtual instruction, and whether modifications to the IEP are needed. For more information see the Department of Education’s guidance.

Q. What are my responsibilities under the Family Educational Rights and Privacy Act (FERPA)?

The Department of Education has provided detailed guidance regarding sharing and reporting student information such as extended absences and illness. This information is largely targeted at school administrators and is generally related to disclosing information to public health and medical personnel. However, it is important to remember that under FERPA, you should not disclose personally identifiable information about the health status of a particular student, teacher, or other school personnel to the general public.

Q. Are early intervention services to infants and toddlers with disabilities still required during an outbreak?

If the office of the state lead agency or EIS program or provider is closed, early intervention services under Part C of the IDEA are not required. If the office remains open, and services cannot be provided in a particular location (e.g., the child’s home or daycare setting) or by a particular provider, the lead agency must ensure continuity of services. If an office has closed, after it reopens the individualized family service plan (IFSP) team should determine whether the IFSP is still appropriate, or needs updating.

Q. What are some alternatives for service provision if services cannot be provided in a particular location (such as a child’s home) or by the current service provider?

Examples include providing services in an alternate location, using a different EIS provider, or exploring an alternate means, such as consultative services to the parent. Determining the specific method employed should be on a case-by-case basis, consistent with the most updated public health and safety guidance, in coordination with the child, family, and state lead agency or EIS program or provider. For more information see the Department of Education’s guidance.

Guidance for OT/OTA Students

We know this is also an unprecedented time for students and educators alike. Each college and university is making individualized decisions regarding face to face classes and fieldwork. We recommend you frequently monitor your student email account and communicate with your faculty as questions arise. Taking campus-based classes to a virtual format requires flexibility from all parties. Now is a time for patience, flexibility, and grace as things are changing on a daily basis.  Students should know that faculty are diligently working to make this transition to alternate teaching methods as seamless as possible for students. OOTA will continue to support educators and students in whatever way we can throughout the duration of this pandemic.

Coping with Covid-19 Anxiety

There are an abundance of resources available for stress management and coping with the unusual circumstances in which we find ourselves. Ohio has a good resource here with multiple resources available for you and your families. 

Please continue to support each other as we move through this time together. And let us know what we can do to help you.