The American Physical Therapy Association and APTA Pediatrics are working to keep practitioners abreast of current concerns and precautions as the spread of COVID-19 progresses. Regulations are changing quickly and are difficult to keep up with both for our organization as well as for individual practitioners.
Practitioners are increasingly exploring alternative service delivery models. Terms such as “telemedicine”, “telehealth”, “tele-intervention”, and “telepractice” are used interchangeably to describe the delivery of health care services using information and communication technology.
APTA Pediatrics would like to address questions regarding telepractice that have been raised by our membership. There is no clear-cut determination or one-size-fits-all solution regarding telepractice for pediatric services, even in an unusual situation such as the one we are now facing. The regulations are fluid and change quickly.
Each practitioner must take responsibility for knowing the legal, state, federal, organizational, and ethical rules that regulate alternative service delivery models. A great deal relies on the case, specific considerations of each context/situation, clinical reasoning, and the individual determination by the practitioner of whether telepractice is appropriate.
No matter what service delivery model your employer or organization is trying to establish, you are ultimately responsible for the legal and ethical delivery of PT services. We encourage you to consider each of the following prior to initiating telepractice:
- Know exactly what service delivery model you are considering. There is a differentiation between e-visits and other telehealth models. E-visits must be initiated by the “patient,” the patient must be an established patient for the provider, and the visit must be delivered through an already established patient portal.
- Consult your state regulatory board to determine whether telepractice for physical therapists is within the scope of practice for your state as this is a state by state decision. As of November 2019, there were only 16 states which included “telerehabilitation” within their practice act.
- Consult the agency, clinic, hospital, program, or school district you work for to determine whether telepractice is approved or will be supported.
- If you are serving Medicaid patients, consult your state agency to see if telepractice is reimbursable and, if so, what is appropriate coding. This again is a state by state decision.
- Ensure that the patient/family insurance carrier will reimburse for telepractice and determine appropriate coding.
- Ensure that any vehicles used for telepractice (eg, computers, storage, internet carriers) meet HIPAA and/or FERPA requirements.
- Consult the law if you work in a setting under IDEA part B or part C. Changes to service delivery in an IFSP or an IEP require team consensus and a formal IFSP or IEP change of location of service.
- Check to see that your malpractice covers you when providing services via telepractice.
- Ask if special training is required to qualify practitioners to provide telepractice.
- If you deem that telepractice is legal and safe for your practice, you must then make a determination that telepractice is helpful and ethical on a case by case basis for each patient and family you serve. You must also give thoughtful consideration to the qualifications and training required by the “on-site” person who carries out your interventions.
- Does your organization have telepractice policies and procedures addressing situations such as emergencies?
Below are links to websites that might be helpful to gain greater insight into the issues that must be addressed prior to changing a service delivery model. Every effort will be made to update this document and the links below given the time complexities for the volunteers who are generously sharing their time for the benefit of our profession during this challenging time.
GENERAL TELEPRACTICE
APTA resources:
Additional APTA Pediatrics resources:
Medicaid and Medicare resources:
SERVICE DELIVERY IN SCHOOLS:
- March 30, 2020: A couple of important takeaways form the CARES Act: 1) 30 billion was allocated to the Elementary and Secondary Schools Emergency Relief Fund, which can be used for IDEA, 504, and other disability instruction and services. It will be critical for state and local advocates to immediate interact with their state Departments of Education and local school districts about how those funds will be used to support students with disabilities. 2) $150 billion was allocated to state and local governments. As with the school funds, stakeholders will need to advocate for the use of these funds to provide blind, deaf, developmental disability, vocational rehabilitation, and other disability services.
- March 2020: Department of Education, Providing Services to Children with Disabilities During the Coronavirus Disease 2019 Outbreak: https://www2.ed.gov/policy/speced/guid/idea/memosdcltrs/qa-covid-19-03-12-2020.pdf?utm_content=&utm_medium=email&utm_name=&utm_source=govdelivery&utm_term=
- March 2020: Student Privacy Policy Office FERPA & Coronavirus Disease 2019 (COVID-19) Frequently Asked Questions (FAQs): https://studentprivacy.ed.gov/sites/default/files/resource_document/file/FERPA%20and%20Coronavirus%20Frequently%20Asked%20Questions_0.pdf?utm_content=&utm_medium=email&utm_name=&utm_source=govdelivery&utm_term=
- CDC’s Coronavirus Disease-2019 (COVID-19) Guidance for School Settings has been updated and is posted at: https://www.cdc.gov/coronavirus/2019-ncov/community/schools-childcare/index.html.
- 2016 OSEP Guidance on Virtual Schools: https://www2.ed.gov/policy/speced/guid/idea/memosdcltrs/dcl--virtual-schools--08-05-2016.pdf
- Helpful perspectives for school PTs: https://sites.google.com/view/sbptcovid-19perspectives/home
- Early Childhood Technical Assistance Website: https://ectacenter.org/topics/disaster/tele-intervention.asp#additional
- Department of Education, supporting Early Childhood and Early Intervention with telehealth: https://www.dec-sped.org/ei-ecse-resources-covid-19
SERVICE DELIVERY IN EARLY INTERVENTION:
SERVICE DELIVERY IN HOSPITALS AND OUTPATIENT FACILITIES:
PRIVATE PRACTICE
Visit APTA Pediatrics (https://pediatricapta.org/) and APTA’s Coronavirus page (http://www.apta.org/Coronavirus/) for additional information as the situation evolves.
