Add COTAS as Teletherapy Providers under CMS Guidelines

Add COTAS as Teletherapy Providers under CMS Guidelines

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Diane Randall started this petition to Centers for Medicare and Medicaid Services Office of Legislation Alec Aramanda

The Covid-19 Pandemic is impacting us all; but for children with special needs, the impact can be even more detrimental especially when care is not taken to preserve essential services and important routines. Many children with special needs thrive on consistent routines and therefore, are greatly impacted even with the smallest change to those routines. Many patients grow up attending weekly therapy sessions provided by dedicated Certified Occupational Therapy Assistants under the Supervision of Occupational Therapists. These services are crucial to children's social, motor and cognitive development. In a clinic setting, COTA's follow through with treatment plans established by OTRs. These essential therapists provide treatment to children with Autism, CP, down syndrome and other developmental and physical delays.  Recent social distancing mandates have forced those in the Pediatric Occupational Therapy field to rethink how to deliver services safely.  The Centers for Medicare and Medicaid Services has rightly acknowledged the importance of using telehealth to deliver essential therapy services as cited below.

This excerpt is from  COVID-19 Emergency Declaration Blanket Waivers for Health Care Providers. ( updated 4/21)

Flexibility for Medicare Telehealth Services (New since 4/21 Release)


• 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.
  
See link below for state by state requirements. Most states do not have any exclusions for Occupational Therapists or Assistants to provide Telehealth Services.

https://www.aota.org/~/media/Corporate/Files/Advocacy/State/telehealth/Telehealth-State-Statutes-Regulations-Regulatory-Board-Statements.pdf

Teletherapy is currently being provided to Cyber-school students by Certified Occupational Therapy Assistants  to address IEPs goals.

Prior to Covid-19, COTAS, played a crucial role in the lives of special needs children in the insurance based clinic setting and have been able to bill for Medicare/Medicaid Services. Eligible practitioners are assumed to be Certified Occupational Therapy Assistants. Private insurance company's often have polices that follow CMS guidelines. Unfortunately, as a result of vague wording and lack of specificity in the CMS guidelines, many COTAS have been furloughed or laid off. 

As of May 5 ,2020 AOTA ( The American Occupational Therapy Association) has clarified that COTAS and PTAS can deliver telehealth services under certain conditions. See link for details

https://www.aota.org/Advocacy-Policy/Federal-Reg-Affairs/News/2020/Billing-Telehealth-Services-Medicare.aspx


We are asking CMS to specifically mention "Certified Occupational Therapy Assistants" and our colleges "Physical Therapy Assistants"  as providers. In addition it is requested  that language will be amended so that the guidelines will become more clear to employers who are presently hesitant to allow assistants to use teletherapy to treat patients for fear of insurance denial. As in the clinic, Occupational Therapists would continue to develop treatment plans and Supervise COTAS. Teletherapy can even be provided in the clinic setting with careful social distancing between staff. 


Currently, many children, especially in disadvantaged communities,  are simply going without any therapy services because COTA caseloads simply cannot be absorbed by treating Occupational Therapists. Routines have been disrupted by stay-at-home-orders. Familiar therapists have simply disappeared from children's lives. By amending the current guidelines mentioned above, Certified Occupational Therapy Assistants will once again be able join the therapy team to make a difference in the lives of special needs children.


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