COVID-19: Updates and Resources
General Information |New Jersey Legislative Updates | NJ School Settings | Audiology/Hearing Loss | NJ Early Intervention Professional | Higher Education Issues/Clinical Supervision | NJ Private Practice and Health Care Issues | Resources
Information continues to change daily. If you are having concerns about COVID-19 and seeing patients contact the local board of health in the town your facility is located.
The New Jersey Speech-Language Hearing Association (NJSHA) supports priority access to COVID-19 vaccines approved by the Food and Drug Administration for audiologists and speech-language pathologists who provide in-person assessment and treatment services. The services that we provide are essential for individuals with communication, swallowing and cognitive disorders. While some have provided services remotely, others, who work in settings such as hospitals, skilled nursing facilities, clinics and schools, have not. Even with strict adherence to mask-wearing and social distancing, our members are at greater risk for acquiring the COVID-19 virus because of the need to interact closely with patients, clients or students. In some cases, adequate personal protective equipment is not available, and yet our members, recognizing that human communication is essential, risk their lives to serve those with communication and related disorders.
As the COVID-19 vaccine distribution continues, we encourage you to review the distribution phases in New Jersey to determine when you will be eligible for the vaccine. The Centers for Disease Control (CDC) has a link to each state vaccination distribution plan: https://www.cdc.gov/vaccines/covid-19/covid19-vaccination-guidance.html.
NJSHA will continue to advocate for priority vaccine access for our members recognizing that effective communication is essential and that our members will continue to provide needed services regardless of personal risk.
- Federal Public Health Emergency Extended
- CDC COVID Vaccine State Update
- ASHA Press Release Calls for Priority Access for Audiologists and SLPs to Approved Vaccines
On behalf of NJSHA, thank you for all the services that you provide to individuals with communication disorders. We appreciate the work and dedication of each one of you, not only during these difficult times but every day.
Vax Matters: Sign up to receive the latest vaccine news and updates from the State of New Jersey Department of Health
NJSHA has sent a formal letter to Governor Murphy requesting that SLPs and audiologists be recognized as healthcare and childcare professionals and be included in the first group of citizens eligible to receive the COVID-19 vaccine.
The vaccine is available for healthcare workers who live and/or work in Hudson County. Click here to learn more.
NJSHA also recommends regularly checking the CDC website for general guidance.
New Jersey Legislative Updates
Please visit our Current Issues in NJ Legislation webpage to see all legislative issues related to different work settings.
NJ School Settings
“The administrative orders, directives, and waivers issued by any Executive Branch departments and agencies in whole or in part based on the authority under the EHPA to respond to the previously declared Public Health Emergency presented by the COVID-19 outbreak that are provided in the Appendix to this Order shall remain in full force and effect unless otherwise modified or revoked by the Executive Branch department or agency.”
To read full text please visit: https://www.nj.gov/infobank/eo/056murphy/pdf/EO-281.pdf
NJSHA will continue to monitor this Executive Order for any changes. Please continue to check back often for updated information.
Updated January 12, 2022
Governor Murphy Reinstates the Public Health Emergency
On January 11, 2022, Governor Murphy reinstated the Public Health Emergency (PHE) and extended various regulatory actions with Executive Orders (EO) 280 and 281. Although not listed individually, the language within “various regulatory actions” includes those listed within the appendix of EO 281. Within this appendix, the Temporary Rule Modification to N.J.A.C. 6A:14 is listed, which covers the use of teletherapy within the schools.
Governor Murphy’s reimplementation of the PHE means that at least for the next 30 days, virtual related services may be provided in schools.
NJSHA will continue to post updates as they become available.
To read the full article please visit https://nj.gov/governor/news/news/562022/approved/20220111d.shtml
Appendix of Executive Order 281 can be found at: https://nj.gov/infobank/eo/056murphy/pdf/EO-281-APPENDIX.pdf
Updated October 4, 2021
Extension of the Temporary Rule Modification
Governor Murphy’s Temporary Rule Modification that allowed related services to be provided virtually has been extended to January 11, 2022. This is one of the determinations made at the NJ Department of Education meeting that was held September 8, 2021. To read the full text please visit
NJSHA is currently working on a position statement on teletherapy in the schools. Please check back often for updates on this.
Update September 8, 2021
State of New Jersey Issues Guidance for K-12 Schools
The 2021-2022 school year is now upon us. As most New Jersey schools re-open their doors to in-person learning, there is no doubt there are mixed feelings among students, parents and school staff. To help address some of the common concerns, the New Jersey Department of Health has updated its guidance on the COVID-19 Public Health Recommendations for Local Health Departments for K-12 Schools.
- Recommendations on Communication
- Social Distancing and Cohorting
- Hand Hygiene and Respiratory Etiquette
- Cleaning, Disinfection and Airflow
- and more…
To read more, please visit: https://www.njsha.org/pdfs/k12-guidance-0821.pdf.
Updated May 24, 2021
2021-2022 School Year: What’s Ahead?
On May 17, 2021, Governor Murphy made an announcement stating “schools will be required to provide full-day, in-person instruction, as they were prior to the COVID-19 Public Health Emergency” for the start of the 2021-2022 school year. You can view the entire announcement by visiting https://nj.gov/governor/news/news/562021/approved/20210517a.shtml, which was published to the State of New Jersey website.
NJSHA’s School Affairs Committee awaits official notification from the State of New Jersey’s Department of Education regarding the status of remote special education and related services.
Please check the NJSHA website regularly as we will be posting developing information on this topic.
Update March 22, 2021
Update on Billable Teletherapy Services in the School Setting
In February 2021, NJSHA’s School Affairs Committee (SAC) had a videoconference meeting with representatives from the New Jersey Department of Human Services, specifically the Division of Medical Assistance and Health Services to discuss the impact the pandemic has had on the provision of speech-language pathology services under SEMI. On the call with SAC were individuals from the Department of Human Services: Medicaid’s Medical Director, the Chief of Behavioral Health, the Deputy Director and the Director of Managed Provider Relations.
Below is the clarification received on some of the key points discussed regarding what is considered a billable service under SEMI for teletherapy services in the school setting. NJSHA is currently awaiting written confirmation of this clarification.
Speech-language specialists (SLSs) who are SEMI qualified providers:
- May bill SEMI for services provided directly to the students utilizing the best platform available to SLSs during an emergency situation as long as it is direct contact and emulates what would be provided in typical times and in a face-to-face session.
- May bill SEMI for such direct services provided for New Jersey students who temporarily are residing in another state during this COVID emergency situation.
- May NOT bill SEMI for such direct services provided for New Jersey students who temporarily are residing in another country (i.e., outside the United States of America).
- May NOT bill SEMI for asynchronous therapy services provided (e.g., packets or taped programs).
Once again, this information was conveyed verbally by Medicaid officials and heard by NJSHA SAC representatives as well as NJSHA’s lobbyist. NJSHA claims no responsibility for misinterpretations as we await confirmation in writing.
Update November 9, 2020
Out of State Students and SEMI Billing
On October 29, 2020, NJSHA School Affairs Committee (SAC) wrote to NJ Department of Treasury and NJ Division of Human Services in order to gain clarity on this frequently asked question and several others regarding SEMI billing during the COVID-19 pandemic. SAC is currently in process of setting up a call with it’s Lobbyist and the Director of Medicaid in NJ to receive the information.
While SAC is awaiting further information, you may find searching ASHA’s COVID-19: TRACKING OF STATE LAWS AND REGULATIONS FOR TELEPRACTICE AND LICENSURE POLICY at https://www.asha.org/siteassets/uploadedfiles/state-laws-and-regulations-for-school-based-telepractice.pdf to be helpful. This site has current state-by-state information regarding emergency provisions for providing services out of your state licensure.
Relative to the question of providing SLP services for a student who has temporarily moved out of the state/country, there is no simple answer. In typical times, once a student moves out of a district, the district’s obligation to provide services/education ends. Under the speech-language specialist (SLS) endorsement, SLSs can treat a student temporarily living in another state/country due to the temporary rule modification by the NJDOE allowing use of teletherapy, as long as the student remains registered at the NJ school district. However, at this time, it is unclear whether or not the service is billable under the Special Education Medicaid Initiative (SEMI). Though the NJ Division of Consumer Affairs (the licensing authority in NJ) does not have jurisdiction over the NJDOE endorsement, SLS, SLSs who are licensed by that entity or who have their CCC from ASHA are obligated to follow the code of ethics of both entities, which is important for many reasons including their continued ability to sign off on Medicaid.
ASHA has recommended additional steps to take for Delivering Services to Students Internationally which can be found at https://www.asha.org/advocacy/serving-students-in-other-states-and-countries-through-telepractice/
Update July 24, 2020
Navigating the Road Back to School for the SLS
NJSHA—WORKING TOGETHER TO WORK FOR YOU!
Back to school usually represents excited anticipation for speech-language specialists (SLSs). This year, as school bells ring, SLSs will more likely be filled with nervous anticipation about their students’ and their own health and safety during the uncertainties of COVID-19. The New Jersey Department of Education (NJDOE) invited NJSHA to provide recommendations and input regarding best practices when responding to emergencies similar to this unique situation and to address future areas of concern.
With this in mind, your NJSHA School Affairs Committee (SAC) spent many hours and recently completed and delivered to the NJDOE a detailed document speaking to the use of school-based telepractice in emergency situations, including technical needs of SLSs and students; therapy and assessment; and reopening /recovery suggestions for personal and environmental health.
School-Based Speech-Language Pathology Services During Emergency Situations: A Guide for Practitioners and Districts is meant to provide New Jersey SLSs with suggestions and guidelines related to service provision during emergency situations.
NJSHA is delighted to have been invited to participate in the process and to provide input and information to ensure SLSs and students are best served. Much appreciation goes to those NJSHA members who contributed to researching, writing, discussing and editing this document.
- Yesenia Concepcion-Escano, MA, CCC-SLP
- Mary Faella, MA, CCC-SLP
- Mary Anne Ferraioli, MS, CCC-SLP
- Nicole Ford, MS, CCC-SLP
- Sue Goldman, MA, CCC-SLP
- Stacey D. Johnson, SLPD, CCC-SLP
- Robin Kanis, MS, CCC-SLP
- Leanne Merlo, MA, CCC-SLP
- Maria L. Rodriguez, SLPD, CCC-SLP
- Linda Tucker-Simpson, MS, CCC-SLP
- Joan Warner, MS, CCC-SLP
Additional resources to help prepare for back-to-school include reading ASHA’s position statement regarding reopening schools, https://www.asha.org/Advocacy/Advocacy-Position-on-Reopening-Schools/ and the CDC and ASHA’s recommendations for safety while providing therapy:
“The CDC recommends working with the same group of students on a regular basis to reduce the risk of contracting COVID-19. Because audiologists and SLPs work with different students throughout the week and may travel to multiple schools to provide services, they may be at greater risk. The CDC recommends the provision of telework as an option.” https://www.asha.org/Practice/Resuming-Services-in-Schools-During-COVID-19/
Audiology/Hearing Issues Loss
Update August 21, 2020
NJSHA’s Audiology Committee is committed to helping our members be aware of the latest issues related to the impact of the novel coronavirus on the individuals we serve. The published information related to the impact of the COVID-19 pandemic can be viewed from three different perspectives. We can consider the impact of the virus itself on the hearing mechanism and on auditory acuity and processing, and the impact of the medication used to treat the virus, and the impact on communication with individuals with hearing loss when using masks or other face coverings.
Relationship between COVID-19 exposure and hearing loss.
The findings that have been published to date regarding the impact of the virus on the hearing mechanism has been anecdotal and has not been derived from carefully controlled large scale studies. For example, there is was a note published in the American Journal of Otolaryngology in 2020 (1) in which the author reported on the coincident finding of hearing loss in “an old female “in Thailand who was diagnosed with COVID-19. This anecdotal report should not be interpreted to indicate that COVID-19 causes hearing loss.
In a slightly larger study (N=20 participants) published in the American Journal of Otolaryngology (2) suggested that the participants who were asymptomatic yet tested positive for COVID-19 had normal hearing thresholds but had average TEOAE amplitudes that were slightly although significantly poorer (1.3 in unspecified units) than the control group.
At this point it is important to note that those who are most vulnerable to the effects of the coronavirus are those who have co-morbid conditions. In many cases hearing loss is but one of the co-morbidities. As such, the pre-existing conditions must be considered before any clear causal relationship between the coronavirus and hearing loss can be drawn.
In a Research Letter published in the JAMA Otolaryngology-Head & Neck Surgery, the investigators explored the possibility that the virus invaded the middle ear and mastoid.(3) These researchers reported on the results of post-mortem examinations of the mastoids and middle ears from 3 individuals who expired and were positive for COVID-19. The findings confirmed the presence of the virus in the middle ear and mastoid. This report does not include information regarding the auditory status of the individuals, so it is impossible to determine if there is a link between the virus and any loss of hearing. The authors concluded that physicians who may see individuals for middle ear or mastoid procedures to exercise caution as there is reason to suspect that the virus can be aerosolized, or droplets may be generated during the procedure.
In conclusion, there is no clear evidence that COVID-19 causes hearing loss. If, at some point in the future, scientists can truly isolate the mechanisms and impact of the virus on the auditory system that will be helpful to eliminate or mitigate the impact of the virus.
On the other hand, there is plenty of evidence of the impact of other viral infections on the structure and function of the ear (e.g., CMV, HIV, Rubella). So, while the data published to date cannot support a cause and effect claim, audiologists should continue to monitor the situation as larger and more robust studies are published.
- (1) Sriwijitalaia W, and Wiwanitkitb V. Hearing loss and COVID-19: A note. Am J of Otolaryngol Published online Apr 2, 2020. doi: 10.1016/j.amjoto.2020.102473
- (2) Mustafa, M. Audiological profile of asymptomatic COVID-19 PCR-positive cases. Am J of Otolaryngol Published online 10 April 2020. doi: https://doi.org/10.1016/j.amjoto.2020.102483
- (3) Frazier KM, Hooper JE, Mostafa HB, Stewart CM. SARS-CoV-2 virus isolated from the mastoid and middle ear: implications for COVID-19 precautions during ear surgery. JAMA Otolaryngol Head Neck Surg. Published online July 23, 2020. doi:10.1001/jamaoto.2020.1922
Possible impact of the medications used to treat COVID-19 on hearing loss.
Many of the medications that have been used to treat the symptoms of COVID-19 are known to be ototoxic. In a Letter to the Editor published in the International Journal of Immunopathology and Pharmacology(4) , the authors warn clinicians about the possible ototoxic side effects of chloroquine and hydroxychloroquine, azithromycin and the antiviral drugs such as remdesivir, favipiravir and lopinavir. While the biochemistry and the specific impacts of these medications is beyond the scope of this article suffice it to say that an ototoxic reaction to these medications is not to be taken lightly. The known reactions to these medications can contribute to hearing loss, tinnitus and loss of balance. As audiologists, we understand that these changes can impact the quality of life (QoL) for the individuals we serve. We are also acutely aware of the impact of these changes in QoL and mental well-being.
So, if there is hearing loss or loss of balance function in patients who have tested positive for COVID-19 we must do our best to minimize the impact of these on the communication function of the individuals we serve; regardless of the underlying cause of the hearing/balance loss.
- (4) Ciobra A, Corazzi V, Skarżyński P, Skarżyńska M, Bianchini C, Pelucchi S, Hatzopoulos S. Don’t forget ototoxicity during the SARS-CoV-2 (Covid-19) pandemic! Int J Immunopathol Pharmacol., Published online 2020 Jul 10. doi: 10.1177/2058738420941754
Impact of face masks on communication.
A discussion of the effects of COVID-19 on individuals with hearing loss would not be complete without considering the impact of the CDC recommended use of cloth face masks/face coverings on communication. As audiologists we are concerned that this advice puts individuals with hearing loss, regardless of the cause of the loss, at a significant disadvantage when trying to communicate in these unprecedented times.
According to the NIH, there are approximately 37.5 million adults with hearing loss in the United States. Most of the individuals with hearing loss rely on their eyes to speech read to supplement the auditory input they are able to receive through various devices like hearing aids and cochlear implants. The recommendation to use a solid face cloth/mask eliminates the ability of individuals with hearing loss to use visual and facial cues. Furthermore, many of the individuals who are at the highest risk for serious complications from the COVID-19 virus are also the most likely to have hearing loss. The NIH reports that nearly 25 percent of individuals between 65 and 74 years and 50 percent of those over the age of 75 years have disabling hearing loss.
The best solution to this issue while maintaining safety and reducing the spread of the COVID-19 virus is to use clear masks or masks that have a clear window. This solution allows all individuals with hearing loss to take advantage of the cues provided by speech reading and other facial cues. We have received reports from individuals who we serve that they have gone to medical appointments and have had practitioners who have refused to remove their masks or to write notes to improve communication.
The Hearing Loss Association of America website has some very practical ideas to manage communication difficulties in these challenging times. As an example, a placard found at this link can be printed and taken to appointments.
NJ Early Intervention Professional
Update April 29, 2020
This US Dept of Education report states Part C services (Early intervention) can continue for toddlers that would be transitioning to PART B (school based) until an in-person evaluation can take place. See page 11 of this report from US DOE. Re: IDEA. https://www2.ed.gov/documents/coronavirus/cares-waiver-report.pdf
Update March 23, 2020
Update March 17, 2020
Higher Education Issues/Clinical Supervision
NJSHA will continue to post updates as they become available.
Updated August 17, 2021
Virtual supervision of those SLPs working under a temporary license may continue until January 11, 2022. This is stated in the following order:
C.26:13-34 Expiration of orders, directives, waivers issued due to public health emergency.
- a. Following the termination of the public health emergency declared by the Governor in Executive Order No. 103 of 2020, as extended, the force and effect of any administrative order, directive, or waiver issued by the head of a State agency that relied on the existence of the public health emergency declared by the Governor in Executive Order No. 103 of 2020, as extended, shall expire on January 11, 2022. Such administrative order, directive, or waiver may be continued and may be modified by the head of a State agency, unless such administrative order, directive, or waiver is explicitly revoked, until January 11, 2022
Update July 31, 2020
Since March, NJSHA has been in regular communications with the Audiology and Speech-Language Pathology Advisory Committee (New Jersey’s licensing board) to address the requirement that those holding a temporary license (CFs) must have on-site supervision. We are very pleased to inform you that an Administrative Order has been signed which waives the on-site supervision requirement and allows supervision to be conducted virtually, using audio and video technology. The text that pertains to SLPs and audiologists is:
Audiology/Speech Language Pathology: N.J.A.C. 13:44C-3.5(f) is waived to the extent that it requires that direct, face-to-face evaluation of therapeutic services by temporary licensees of the Audiology and Speech Language Pathology Advisory Committee be provided on-site. Temporary licensees may instead be supervised via electronic means with a video component.
This order shall remain in effect until the end of the state of emergency or public health emergency declared by the Governor in EO 103, whichever is later. View Administrative Order 2020-14 and Waiver 2020-13.
NJSHA would like to thank members of the Advisory Committee, Department of Law and Public Safety and the Division of Consumer Affairs for their support to accomplish this waiver.
Update May 19, 2020
The Council for Clinical Certification in Audiology and Speech-Language Pathology (CFCC) continues to monitor the COVID-19 pandemic and its impact on our profession.
Hearing the continued and long-term impact of the pandemic on your programs, plans and deadlines for the fall semester planning, and hearing how your programs quickly adapted to our new environment without sacrificing client/patient care and safety was greatly appreciated by the CFCC. During conference calls on May 15, 2020, the CFCC agreed to make additional accommodations to assist you and your students. There is also updated information regarding availability of Praxis examinations. Please share the information below with your students and colleagues.
- Speech-Language Pathology (SLP) accommodations for graduate student telepractice while being telesupervised: Clinical educators may telesupervise concurrent sessions delivered via telepractice as long as they supervise a minimum of 25% of the total contact time with each client/patient and are 100% accessible to the student. The number of concurrent sessions is up to the discretion of the clinical educator, their program director, and the program, and must comply with Council for Academic Accreditation (CAA) accreditation standards and with local, state, or federal laws regarding telepractice and telesupervision.
- Accommodations to the audiology and SLP certification standards have been extended through 12/31/2020 for programs that are unable to provide onsite in-person services due to COVID-19.
- In recognition of the essential healthcare services that audiologists and SLPs provide, the Audiology and SLP Praxis exams are now available at ETS testing centers that are permitted to be open by state and local officials. As of 5/15/2020, over two-thirds of ETS testing centers have reopened and more are reopening each week. For more information please visit www.ets.org/praxis. In addition, the Praxis at Home option also began on May 18, 2020 for the SLP Praxis.
Update April 29, 2020
The NJ Division of Consumer Affairs, Licensing Board has provided assurance that CFs may practice telehealth by statute in the Uniform Enforcement Act N.J.S.A. 45:1-62 et al.
Further, the Division is posting an alert on its website indicating clinical interns (i.e. CFs) who are two months away from the end of their supervision may submit the specified temp to perm application materials to Renee Clark via email. The Division has been licensing temp to perm individuals, as well as others. The specific information required to process temp to perm is being posted to the Division’s website.
The Division has advised NJSHA it is working on a solution to the on site direct supervision requirement. We will post any updates as we receive them.
Update April 22, 2020
ETS Professional Education Programs announces Praxis® at Home option due to the closure of testing centers. Read More from ETS.
Update April 15, 2020
Temporary Licensure Supervision Requirements for Clinical Fellows (CFs)
The present NJ licensure regulation N.J.A.C. 13:44C-3.5(f) states that “The supervisor shall provide a minimum of one hour of on-site direct supervision for each 20 hours of direct, face-to-face evaluation or therapeutic services rendered by the supervisee. Supervision shall take place not less than once a month” NJSHA is aware that this “onsite” supervision mandate does not currently allow for the CF to meet the supervision standard of “on-site” when performing telepractice services if the supervisor is not on-site. Given the current climate of COVID-19 and the extended mandatory “stay at home” order, this affects any Clinical Fellowships in process under a temporary license.
In response, NJSHA has submitted a letter to the licensing board on behalf of all NJ Clinical Fellows, asking for a temporary waiver of the “on-site direct” supervision requirement and requesting that “live direct supervision” be allowable during COVID-19. If approved, synchronous remote supervision of telepractice would allow for CF’s under a temporary license to continue to provide necessary services to be able to meet the requirements for permanent licensing.
The licensure board is aware of the issue that the on-site supervision requirement poses for clinical fellows and their respective supervisors. They are working to address this provision so that clinical fellows with temporary licenses can practice telemedicine without concern that they are not compliant with the regulation.
NJSHA is closely monitoring the situation and will provide any updates as they become available. Please also note, this applies only to CF’s practicing under a NJ temporary license.
Update April 9, 2020
Telesupervision and Telepractice guidelines for Graduate Student Interns
Graduate student clinicians enrolled in CAA-accredited and CAA-candidacy programs can engage in service delivery through telepractice when the clinical educator provides 100% direct supervision of the sessions in real time, either side-by-side with the student or with the student, the clinical educator, and the client/patient in different locations. This allowance is for both audiology and speech-language pathology programs.
Read the full statement here: https://www.asha.org/Certification/COVID-19-Use-of-Telepractice-and-Telesupervision/. Universities should contact their compliance officers and check the most recent federal guidance in order to determine which telepractice platforms would be considered HIPAA-compliant.
Please note the extension to August 1st of previous ASHA/CFCC guidance, which allows graduate student interns to collect clinical hours through distance learning (i.e., telepractice) in both university-based clinics and community clinical sites.
Update March 23, 2020
University students, faculty, and staff are grappling with a difficult reality, and have many questions about how clinical clock hours can be obtained in the context of COVID-19. With regard to telesupervision, we encourage members to follow ASHA and CAA guidance on this matter, as clinical supervision guidelines are not governed by individual states. With regard to telepractice however, in addition to ASHA and CAA guidelines, all state certification and licensure policies must also be adhered to.
We have gathered some of the pertinent information here, for your reference. ASHA’s Council for Clinical Certification (CFCC) released a special statement related to telepractice and telesupervision during the COVID-19 pandemic on March 13, 2020. They state:
“Graduate student clinicians enrolled in CAA-accredited and CAA-candidacy programs can engage in service delivery through telepractice when the clinical educator provides 100% direct supervision of the sessions in real time, either side-by-side with the student or with the student, the clinical educator, and the client/patient in different locations. This allowance is for both audiology and speech-language pathology programs.”
Read the full statement here: https://www.asha.org/Certification/COVID-19-Use-of-Telepractice-and-Telesupervision/. Universities should contact their compliance officers and check the most recent federal guidance in order to determine which telepractice platforms would be considered HIPAA-compliant.
Additionally, students may obtain up to 75 clock hours via simulation, and asynchronous supervision of simulations is permissible, as long as the supervisor follows best practice guidelines for de-briefing at least 15 minutes per hour of service (25% supervision). See the CFCC statement on supervision of simulations here: https://www.asha.org/certification/certification-standards-for-slp–clinical-simulation/#supervision
NJ Private Practice and Health Care Issues
Telepractice is allowed in New Jersey. NJSHA was involved in the passage of the Telemedicine/Telepractice bill which was signed in 2018. To read about it go to https://www.njsha.org/advocacy/triumphs/. The bill itself can be found at: Telemedicine/Tele-practice (2017) P.L. 2017, c 117. While the 2017 telepractice law does state that services rendered by teletherapy should be reimbursed the same as in person therapy, this is a New Jersey law and only applies to insurance plans written in NJ that are under Dept of Banking and Insurance (DOBI) oversight. Self-funded plans and federal health plans fall under federal oversight (ERISA). Thus, for those plans, NJSHA advises you to check with the insurance company regarding reimbursement for teletherapy.
If you plan to use teletherapy keep in mind the following:
- SLPs who provide telepractice must comply with HIPAA, which means only HIPAA compliant platforms may be used. In order to be HIPAA compliant, the provider/organization must have a Business Associates Agreement (BAA) with the videoconferencing company. (Note there may be a change to this requirement, NJSHA is investigating this and will update this posting as appropriate).
Licensure laws require that the provider hold a license in both the state where the provider is located as well as the state where the client/patient is located.
ASHA has excellent guidelines which can be found at https://www.asha.org/Practice-Portal/Professional-Issues/Telepractice/
ASHA’s guidelines include the following:
- Both you and the client/patient must have sufficient internet speed to engage in videoconferencing. Both need to have a camera and microphone.
- For many patients/clients, someone else will need to be physically present with them during the session.
NJSHA is not a regulating body, and does not provide any mandates or legal guidance. The Private Practice Committee has, however, gathered useful links to information and resources to help our members have access to the most up-to-date information from a variety of sources. As the most current information keeps changing, clinicians and business owners are encouraged to update and revise their plans. The information and resources in this document are provided to supplement your frequent review of data and emerging evidence, independent clinical judgment, and site-specific guidelines.
If business owners or clinicians have specific questions, please feel free to contact the Private Practice Committee at info@NJHSA.org
Staff safety also needs to be in the plan, especially if you have a practice with several clinicians. You may want to discuss the development of the plan with your employees so everyone can feel safe and part of the decision-making process (i.e., suggestions), which can alleviate some anxiety about coming to work. This should include common work areas, break areas, materials and so on. In addition to making sure that employees have the proper protective equipment, be sure to continue to educate employees about the importance of handwashing.
If your practice engages in services that are more invasive, such as oral motor or feeding therapy, you may want to consider the guidelines and suggestions offered by the American Dental Association as this type of contact is considered to be more high-risk procedures.
Ensure there is a sufficient supply of cleaners and personal protective equipment (PPE). This includes masks, cleaners, hand sanitizer, soap and water, disposable gloves. Use of non-prescription, clear glasses can be used to protect eyes from infection instead of a face shield in some situations.
Keep in mind that new information is coming out almost daily, and policies may need to be changed or updated. Be sure to educate yourself and be aware of the most up-to-date information and do your part to the stop the spread of rumors by doing four easy things:
- Find trusted sources of information.
- Share information only from trusted sources.
- Discourage others from sharing information from unverified sources.
- Look up/Double check new information to verify its validity.
To find trusted sources, look for information from official public health and safety authorities. You can find many official sources at coronavirus.gov, through the CDC, OSHA, NJ Department of Health, your local department of health, emergency management websites and social media accounts for trusted information specific to your area. On social media, be sure to check for a blue verified badge next to the account name. This tells you it’s an official account. There are suggested resources at the bottom of this page.
We have compiled a list of procedures some practices have put in place:
- Call clients/parents and remind them about their appointment and your safety measures, including to reschedule if any symptoms of fever or illness are present or if they are quarantined. If you have a release or other documents you want to have reviewed and/or signed, send them to your clients in advance.
- No use of the waiting room.
- If you have to use a waiting room, remove magazines, reading materials, toys and other objects that may be touched by multiple individuals and which are not easily disinfected.
- For those who must use the waiting room, we have also rearranged our waiting rooms to allow for greater social distancing.
- Clean and disinfect public areas frequently, including door handles, chairs and bathrooms.
- No siblings or other additional people in the office.
- Only the patient is allowed in the office. For children who require a caretaker, one adult may accompany the patient. For adults coming in for hearing aid consultations, or those that need a caretaker, one other adult may accompany the patient.
- Parent uses an intercom system to “call” into the office when they arrive and are met at the door for child to be escorted in by the therapist and parent waits in his/her car unless parent is participating in the child’s session.
- Ask patients to arrive on time for their appointments, rather than too early, or to remain in their cars until they are ready to be seen, if that is feasible, because that will minimize the amount of time spent in your waiting room or reception area.
- Upon arrival, screen all who are coming into your office for fever with a no-touch thermometer and complete a checklist to verify there are no overt signs of illness, such as fever, headache, and so on. Keep in mind that children who are infected may have different symptoms than adults including fever, diarrhea, vomiting, rash, red or pink eyes, red cracked lips or red tongue that looks like a strawberry, swollen hands and feet that may also be red, sluggishness or irritability, change in appetite or eating, changes in behavior, abdominal pain, and an enlarged lymph node (gland) on one side of the neck.
- Any patient with a temperature over 100 degrees must reschedule their appointment. Late cancellation fees will be waived if due to COVID-19 symptoms.
- Upon entering and leaving the therapy area hand sanitizing is conducted by therapist and client.
- During speech therapy session, at the SLP’s discretion, children may be allowed to remove their face coverings during the speech therapy session.
- Appointment times are adjusted to allow for time between clients so that all hard surfaces can be cleaned/sanitized between each session.
- Contactless payment options only, such as credit cards.
- All paperwork must be completed electronically prior to the patient’s scheduled appointment.
- Employees or patients who have symptoms when they arrive at the office or become sick during the day should immediately be separated from other employees, customers, and visitors and sent home. They should quarantine for 14 days.
- Employees self-screen every morning by taking their temperature before coming into work. If an employee has a temperature over 100 degrees they must not come into the office and must notify their supervisor. Please note: If you do not have a fever but have other symptoms of COVID-19, contact your supervisor to arrange for sick time or remote work.
- We will not require sick employees to provide a COVID-19 test result or healthcare provider’s note to validate their illness, qualify for sick leave, or return to work. Healthcare provider offices and medical facilities may be extremely busy and not able to provide such documentation in a timely manner.
- Social distancing can be challenging with our pediatric clients. Use of a mask or a mask/face shield combination by the therapist is employed. For pediatric clients that can tolerate it, they wear a mask during the session.
- Use of clear plastic or plexiglass barriers may be useful in therapy sessions or at a reception desk area.
- We also have to keep in mind social distancing and safety of our co-workers and administrative staff, such as in break rooms, bathrooms, and other common areas. PPE should still be worn and surfaces cleaned.
- Telepractice is still a reasonable option for those clients for whom it is appropriate.
- For individuals with complex needs or those who are health impaired, they may be at high risk for contracting viruses and prefer to continue the telepractice model.
For more information about telepractice, here are some helpful links to ASHA resources:
- Perspectives article about an Overview of Telepractice and Best Practices https://pubs.asha.org/doi/10.1044/aac23.1.4
- An overview of telepractice with relevant links https://www.asha.org/practice-portal/professional-issues/telepractice/
Here is an excerpt from one company’s guidelines:
If someone becomes sick or reports confirmed case of COVID-19, CTP will follow CDC guidance on how to disinfect your building or facility if someone is sick (see Resources below for link)
- If COVID-19 is confirmed in a child or staff member</li
- CTP will close off areas used by the person who is sick
- Open outside doors and windows to increase air circulation in the areas
- Wait up to 24 hours or as long as possible before you clean or disinfect to allow respiratory droplets to settle before cleaning and disinfecting
- Clean and disinfect all areas used by the person who is sick, such as offices, bathrooms, and common areas
- Area may be used again with continued cleaning and disinfection
- If more than 7 days have passed since the person who is sick visited or used the facility, additional cleaning and disinfection is not necessary
- Practice will continue routine cleaning and disinfection
The federally declared public health emergency (PHE) related to the COVID-19 pandemic was renewed on January 14, 2022 for another 90 days. This means that Medicare will continue to reimburse virtual SLP and audiology services at least through April 13, 2022.
More information may be found on ASHA’s website at: https://www.asha.org/news/2022/federal-public-health-emergency-updates-for-2022/
Updated April 12, 2021
Changes to CMS Teletherapy Billing for SLPs and Audiologists
Three important announcements were made by the Centers for Medicare and Medicaid Services (CMS) directly affecting telehealth services for both speech-language pathology and audiology as of March 31, 2021.
PHE is Expected to Last at Least Until the End of 2021.
The federally declared public health emergency (PHE) related to the COVID-19 pandemic is expected to last at least through the end of 2021. Covered services must still be billed to Medicare directly; audiologists and speech-language pathologists cannot directly bill their clients. This extension means that telepractice will continued to be an approved intervention modality. In addition, CMS has expanded the services/ that are billable under Medicare and Medicaid by 24 CPT codes.
Required Modifiers for Telehealth Services
CMS now requires a 95 modifier in addition to the GN modifier currently required.
Additions to the List of Authorized Telehealth Services
The updated list of services increases the number of telehealth-approved CPT codes for direct reimbursement by CMS for speech-language pathology and audiology.
- 92550, Tympanometry and reflex threshold measurements
- 92552, Pure tone audiometry (threshold); air only
- 92553, Pure tone audiometry (threshold); air and bone
- 92555, Speech audiometry threshold
- 92556, Speech audiometry threshold; with speech recognition
- 92557, Comprehensive audiometry threshold evaluation and speech recognition
- 92563, Tone decay test
- 92565, Stenger test, pure tone
- 92567, Tympanometry (impedance testing)
- 92568, Acoustic reflex testing, threshold
- 92570, Acoustic immittance testing, includes tympanometry (impedance testing), acoustic reflex threshold testing, and acoustic reflex decay testing
- 92587, Distortion product evoked otoacoustic emissions; limited evaluation (to confirm the presence or absence of hearing disorder, 3-6 frequencies) or transient evoked otoacoustic emissions, with interpretation and report
- 92625, Assessment of tinnitus (includes pitch, loudness matching, and masking)
- 92626, Evaluation of auditory function for surgically implanted device(s) candidacy or postoperative status of a surgically implanted device(s); first hour
- 92627, Evaluation of auditory function for surgically implanted device(s) candidacy or postoperative status of a surgically implanted device(s); each additional 15 minutes
Speech-Language Pathology Services
- 92526, Treatment of swallowing dysfunction and/or oral function for feeding
- 92607, Evaluation for prescription for speech-generating augmentative and alternative communication device, face-to-face with the patient; first hour
- 92608, Evaluation for prescription for speech-generating augmentative and alternative communication device, face-to-face with the patient; each additional 30 minutes
- 92609, Therapeutic services for the use of speech-generating device, including programming and modification
- 92610, Evaluation of oral and pharyngeal swallowing function
- 96105, Assessment of aphasia (includes assessment of expressive and receptive speech and language function, language comprehension, speech production ability, reading, spelling, writing, e.g., by Boston Diagnostic Aphasia Examination) with interpretation and report, per hour
- 96125, Standardized cognitive performance testing (eg, Ross Information Processing Assessment) per hour of a qualified health care professional’s time, both face-to-face time administering tests to the patient and time interpreting these test results and preparing the report
- 97129, Therapeutic interventions that focus on cognitive function (e.g., attention, memory, reasoning, executive function, problem solving, and/or pragmatic functioning) and compensatory strategies to manage the performance of an activity (e.g., managing time or schedules, initiating, organizing, and sequencing tasks), direct (one-on-one) patient contact; initial 15 minutes
- 97130, Therapeutic interventions that focus on cognitive function (e.g., attention, memory, reasoning, executive function, problem solving, and/or pragmatic functioning) and compensatory strategies to manage the performance of an activity (e.g., managing time or schedules, initiating, organizing, and sequencing tasks), direct (one-on-one) patient contact; each additional 15 minutes (List separately in addition to code for primary procedure)
ASHA has more information about all of the authorized Medicare telehealth services on their website. The ASHA Political Action Committee (PAC) is encouraging all members to help advocate for telehealth service coverage to continue after the PHE. Contact members of Congress and asking them to permanently authorize telehealth services for audiologists and speech-language pathologists by cosponsoring H.R. 2168.
Update from January 8, 2021
Medicare Telehealth Coverage and Other Flexibilities and Waivers
Per Neela Swanson, Director of ASHA Health Care Policy, Coding and Reimbursement email@example.com:
The current federal public health emergency (PHE) will last at least through April 20, extending Medicare telehealth coverage and other flexibilities and waivers.
Because it must be renewed every 90 days, the U.S. Department of Health and Human Services extended the PHE (set to expire Jan. 20) for another 90 days. With the extension, the PHE—in place since Jan. 27, 2020—will have been in effect for more than a year.
The extension keeps many flexibilities and waivers in effect, including Medicare telehealth coverage of audiology and speech-language pathology services and relaxed Health Insurance Portability and Accountability Act (HIPAA) requirements. Many commercial insurers and school districts also have extended enhanced telehealth access for the duration of the PHE.
States and localities, however, may have regulations and policies that expire at different times than the federal PHE. These regulations may include temporary licensure, as well as expansions and flexibilities for Medicaid, commercial insurance, and local education agencies.
ASHA will continue to monitor the status of the PHE and, if circumstances warrant, advocate for a continuation beyond April 20.
ASHA has extensive information regarding service delivery during the COVID-19 pandemic. Contact firstname.lastname@example.org for additional information.
Updated Billing/Coding Requirements for NJ Telehealth Services as of February 10, 2022
Submitting claims to insurance for claims has always been challenging, but more so during the current COVID-related public health emergency and the waiver for coverage for teletherapy services by insurers.
The Private Practice and Healthcare Committees have assembled a list of the requirements by a variety of insurance companies as well as CMS. Thank you to Speech and Hearing Associates for their help compiling this information.
Place of Service codes: Some providers have questioned whether to use POS code 02 or 10 for telehealth. As of now, we believe that the 10 modifier is used primarily for psychiatrists in 2022. SLPs should use the 02 for our purposes (speech therapy). NJSHA continues to investigate this and advises our members to check with individual payers for their specific policy.
Coding telehealth: We are seeing both GT and GQ used. Check with your insurance company to be sure which one is required.
- Horizon Blue Cross Blue Shield of NJ
Teletherapy continues to require a service code of 11 in addition to the GT for telehealth.
Check the address for submitting bill claims as they have different ones depending on the insurance prefix. This includes NJX, YHX, YQX and YHZN plans.
- Horizon BCBS/Anthem, BCBS Out of State Plans
These are “blue card” Horizon plans. They also go to different physical addresses.
These plans now require a place of service (POS) change to 02 and a GT modifier for telehealth.
No change in the POS code but need a GQ modifier for telehealth
Change POS to 02 and add a GT modifier for telehealth
Requires a 95 modifier in addition to the GN modifier
For the other smaller insurance companies, first try changing the POS to 02 and GT modifier, as for Aetna. Be prepared to make an adjustment when/if those claims are denied.
From ASHA (2/1/22):
For outpatient services (e.g., freestanding clinic, private practice, university clinic, etc.) during the current PHE, Medicare requires reporting telehealth services using modifier -95 and the POS code based on where the provider (not the patient) rendered services or would have rendered services if they were in-person. Typically, this would be POS 11 (office). ASHA’s guidance that Meghan provided also outlines the same instructions for Medicare services during the PHE.
Please see Question 5 on page 67 of CMS’s FAQs for more information. Billing for facility-based settings is a little complicated during the PHE, but the FAQs should provide that information as well.
Outside of the PHE, Medicare directs providers to use POS 2 for telehealth services. Given that SLPs aren’t authorized to provide telehealth services outside of the PHE, this guidance generally doesn’t apply to speech-language pathology services. You can see Medicare’s telehealth billing guidelines outside of the PHE in the Medicare Claims Process Manual (the telehealth section starts on page 139).
According to CMS, Medicare has opted not to use POS 10 at this time. Other payers may have a different policy, but that is difficult to track nationwide, especially given the newness of the code. How and when to use POS codes 2 and 10 will depend largely on individual payers. Many may opt to continue using POS 2, like Medicare has, regardless of where the patient is. That said, the key to POS 2 and 10 is the location of the patient, not the provider. Please see ASHA’s standing coding guidance for further information.
NJSHA reminds our members that if you discover changes in billing, or are having trouble getting claims paid, please contact the Private Practice and/or Healthcare Committees. You may not be the only one with a challenge! NJSHA is monitoring reimbursement requirements and wants to provide the most up to date information for our members.
Update from February 10, 2022
- All visit limits continue to apply
- If ST not covered for face to face, then teletherapy not covered either
- If fully funded NJ plan and insurance covers ST, then teletherapy is covered. Co-payments are generally not waived and should be collected.
- If self-funded plan, depends on plan administrator if teletherapy is covered. Many plans have added teletherapy (telehealth) as an ongoing benefit. However some plans do limit telehealth to specific platforms such as TeleDoc, Amwell, MDLive, etc. These platforms do not have SLPs on their panel. Therefore, consumers should be encouraged to speak to their HR department to allow for other platforms in order to access their virtual SLP services.
- If self funded plan, depends on plan administrator if teletherapy is covered
- If plan has a deductible, deductible must be satisfied as per usual for face to face therapy
Please keep in mind that since a teletherapy session is still a speech therapy session, each session counts towards annual limits and/or authorization limits.
Fully funded plans MUST comply with P.L. 2017, c. 117 which mandates that if speech therapy is covered for face to face therapy then it must be covered the same as teletherapy.
NJ Department of Banking and Insurance, Telehealth Response, 3/30/20
Below is information that has been provided from several insurance companies. Please keep in mind that since a teletherapy session is still a speech therapy session:
- 1. Each session counts towards annual limits and/or authorization limits.
- 2. Even for plans that are waiving copays, if the patient has a deductible, the deductible continues to apply and must be satisfied before copay waiver takes effect.
The stated coverage of speech therapy provided by teletherapy assumes that in person speech therapy would be covered. As aforementioned, if the plan does not cover speech therapy provided in person, then it will not cover speech therapy provided by teletherapy.
The insurance companies are currently making many changes and working with limited staff. We have been advised that automated systems are in the process of being updated, and claims may be denied because the systems updates are not completed with so many changes that are occurring. Denials may need to be manually reviewed and reprocessed.
Fully funded plans MUST comply with P.L. 2017, c. 117 which mandates that if speech therapy is covered for face to face therapy then it must be covered the same as teletherapy.
In all cases NJSHA recommends you check the coverage, individual plan benefits, co-insurances and deductibles before initiating teleservices.
Update March 28, 2020
The following resources can be found on ASHA’s website:
- Commercial healthcare plans in the USA:
See table in Private Insurance Coverage of Telehealth for the latest end date
Update: May 7, 2020
Cigna has issued the following update:
The following virtual physical, occupational, and speech therapy (PT/OT/ST) services will be allowed through June 6, 2020 when appended with a GQ modifier and billed with a standard place of service code. These services will be reimbursed consistent with the standard fee schedule.
|92526||Oral function therapy|
- Check the insurance plan to determine if additional CPT codes are covered.
- Please note that while we encourage PT/OT/ST providers to follow CMS guidance regarding the use of software programs for virtual care, we are not requiring the use of any specific software program at this time.
- We maintain all current medical necessity review criteria for virtual care at this time.
See table in Private Insurance Coverage of Telehealth for the latest end date
Update May 7, 2020
The following was in a bulletin sent from Aetna: “Aetna Commercial patients pay $0 for covered telemedicine visits until June 6, 2020. Until further notice, Aetna is also expanding coverage of telemedicine visits to its Aetna Medicare members, so they can receive the care they need from you without leaving their homes. With this change and new flexibilities announced by the Centers for Medicare and Medicaid Services to help combat the virus, Aetna Medicare members can now see their providers virtually via telephone or video.”
Aetna has stated that all plans, whether fully funded or self-funded, will cover teletherapy services with no pay until 6/6/20.
Although the national public health emergency period currently has an end date of July 24, 2020, we know your work is far from over. The following resources will help you quickly reference the effective dates for UnitedHealthcare’s temporary benefit, program and procedure changes related to COVID-19, as well as billing guidelines for services such as COVID-19 testing, treatment and telehealth.
Program Date Summary
Our Summary of COVID-19 Dates by Program outlines the beginning and end dates of program, process or procedure changes that UnitedHealthcare implemented as a result of COVID-19. Full details of these changes, including applicable benefit plans and service information, can be found online. Please be aware of the following key dates:
- June 1 – All currently effective prior authorization requirements and site of service reviews resume.
- June 30 – Claims with a date of service on or after Jan. 1, 2020 will not be denied for timely filing if submitted by June 30, 2020.
- July 24 – COVID-19 telehealth service coverage and related cost-share waivers for Individual and fully insured Group Market health plan members are extended through July 24, 2020. We’ll adhere to state regulations for Medicaid plans.
- Sept. 30 – Cost share is waived for Medicare Advantage members for both primary and specialty office care visits, including telehealth, through Sept. 30, 2020.
To help you understand how UnitedHealthcare will reimburse services during the national public health emergency period, please download the COVID-19 Provider Billing Guidance. It outlines billing codes and modifiers. Because guidance may change, please check regularly for updates.
Update May 8, 2020
United Healthcare posted an update on covered services, including speech therapy and audiology: https://www.uhcprovider.com/en/resource-library/news/Novel-Coronavirus-COVID-19/pa-covid19-updates.html?cid=em-providernews-covid-19nationalemail5-may20
Visit UHCprovider.com/covid19 for their complete COVID-19 resources
Speech Therapy 92507 Treatment of speech, language, voice, communication, and/or auditory processing disorder
Speech Therapy 92521 Evaluation of speech fluency
Speech Therapy 92522 Evaluation of speech sound production
Speech Therapy 92523 Evaluation of speech sound production
Speech Therapy 92526 Treatment of swallowing dysfunction and/or oral function for feeding
Speech Therapy 96105 Assessment of Aphasia and Cognitive Performance Testing
Speech Therapy 97129 Cognitive therapy first 15 minute unit
Speech Therapy 97130 Cognitive therapy for each additional 15 minute unit (use in conjunction with 97129)
Information received from Tricare representative and confirmed on Tricare website. There is no specific end date for teletherapy. Telehealth allowed until the declaration of the end of this national emergency. Per website:
These changes will remain for the duration of the stateside public health emergency.
No out-of-pocket costs for covered telehealth services
- You won’t have out-of-pocket costs for telehealth services that TRICARE covers. TRICARE will now waive your cost-shares and copaymentA fixed dollar amount you may pay for a covered health care service or drug., and deductible (if applicable) for covered telehealth services you get from a military provider or TRICARE network provider. This waiver applies to all covered in-network telehealth services, not just the services related to COVID-19.
- What if you do have to pay? TRICARE can’t immediately waive all copayments and cost-shares. You may have to pay up front and file a claim with your TRICARE contractor for reimbursement. If you have questions, contact your TRICARE contractor.
Referrals and authorizations are still applicable.
Horizon has announced it will continue to cover teletherapy through the public health emergency. The cost share continues to be waived for in network services. After the public health emergency, teletherapy will continue to be covered with applicable patient cost shares. This applies to fully funded (commercial) plans, Medicaid, Medicare Advantage, Individual and Small Group policies, as well as State Health Benefits Program (SHBP), and School Employees’ Health Benefits Program (SEHBP). Other self insured plans may or may not follow this policy, as self insured plans are designed by the employer.
On Horizon website June 29, 2020 – re: telemedicine during COVID-19
On Horizon website June 29, 2020 – re: telemedicine policies generally
Update June 19, 2020
To determine if a plan is fully funded or self funded look at the card.
Fully funded plans will have “HorizonBCBSNJ” written on the back of the card.
Self funded plans will have “Admin only” written on the top right of the card.
All Horizon plans will cover speech therapy provided by teletherapy. Fully funded plans and NJX plans will waive copay. Self funded plans may or may not waive the copay.
Codes Horizon will Cover by Teletherapy
Speech-language pathology codes: 92523, 92521, 92522, 92507, 92610, 92526, 92520, 92524
Audiology codes: 92592, 92593, 99211, 92625 Medicare
The following resources can be found on ASHA’s website:
Commercial healthcare plans in the USA:
Per the American Speech and Hearing Association, State Advocates for Medicare Policy (StAMP) Network monthly network call on 5/5/2020:
Sarah Warren, Director, Health Care Policy, Medicare for American Speech-Language-Hearing Association (ASHA) discussed the Regulatory Components for Telecommunications, and Jerry White, Director of Federal Affairs in Health Care For ASHA discussed the Legislative Progression with Telepractice.
Sarah explained that ASHA, Occupational Therapy Association (AOTA), Physical Therapy Association (APTA) and other providers were on a call with CMS re: Telehealth prior to the StAMP Network Call.
As we already know, speech-langauge pathologists, physical therapists, and occupational therapists were considered suppliers and were unable to bill for telehealth which is no longer the case from a legislative perspective.
- Telepractice is defined as: the Clinic Practice (for our purposes speech therapy and audiology) and the Electronic Platform
- Telehealth is defined as: Legal Payment Policy Concept. Congress WAIVED under the Social Security Act Section 18 that speech-language pathologists and audiologists are suppliers. MDs and practitioners initially were the only ones who were able to provide services under the Legal Payment Policy.
Speech-language pathologists and audiologists in specific settings may now do telehealth during this state of emergency only.
- Telecommunications is the Legal work around/way around to complete Telecommunications: Audio/Visual, Face Time, Skype, Smart Phone, Telephone and E-Visits.
In term of regulations for physical, speech, audiology and occupational therapy:
- Speech-language pathologists/audiologists in PRIVATE PRACTICE may bill for telehealth/telecommunication: audio and visually which includes face time/skyping, smart phone/telephone and e-vite. A modifier must be used, i.e., Modifier 95. There is a limitation of codes. ASHA has not been able to get CMS to approve coverage for ICD 10 Codes for Dysphagia or Cognitive Assessments for Therapy as of yet. ASHA is also seeking coverage for more audiology codes still at this time.
- The Hospital Outpatient Departments (HOPD) are to bill for Telepractice and NOT Telehealth for Medicare outpatients. The outpatients must be REGISTERED as HOME EXTENSION SITES as a TEMPORARY SITE during the Pandemic/Healthcare State of Emergency. This is interpreted as “the patients will be billed as an IN Person Service even though will be treated remotely.” NO MODIFIER WILL BE USED AND THERE IS NO LIMITATION OF ICD 10 CODES for Medicare patients only.
- Skilled Nursing Facilities (SNFs) MUST be ON SITE to Bill for Telepractice. Speech pathologists must be in the building (lobby or another room) of outside the window to conduct Telepractice. This is interpreted as “the patients will be billed as an IN Person Service even though will be treated remotely.” NO MODIFIER WILL BE USED AND THERE IS NO LIMITATION OF ICD 10 CODES for Medicare patients only. ASHA is actively working on this issue.
- Home Health Therapy: is not covered to do any form of Telehealth or Telepractice at this time for Medicare patients. This is an IN PERSON STATUTE which REQUIRES a Legislative Change. ASHA is actively working on this issue.
Update May 1, 2020
Trump Administration Issues Second Round of Sweeping Changes to Support US Healthcare System During COVID-19 Pandemic
Further Expand Telehealth in Medicare:
CMS directed a historic expansion of telehealth services so that doctors and other providers can deliver a wider range of care to Medicare beneficiaries in their homes. Beneficiaries thus don’t have to travel to a healthcare facility and risk exposure to COVID-19.
- For the duration of the COVID-19 emergency, CMS is waiving limitations on the types of clinical practitioners that can furnish Medicare telehealth services. Prior to this change, only doctors, nurse practitioners, physician assistants, and certain others could deliver telehealth services. Now, other practitioners are able to provide telehealth services, including physical therapists, occupational therapists, and speech language pathologists.
ASHA clearly explains the CMS guidelines on SLPs and audiologists billing Medicare during this emergency. Note, this is not a permanent fix. The allowance is retroactive to March 1. View ASHA information.
Update March 26, 2020
E visits for Medicare Part B:
In response to the spread of Corona Virus Disease 2019 (COVID-19), the Centers for Medicare & Medicaid Services (CMS) announced that “clinicians who may not independently bill for evaluation and management visits (for example, physical therapists, occupational therapists, speech-language pathologists, clinical psychologists)” can now bill for three Medicare G-codes for “e-visits,” effective immediately. The e-visit codes allow some qualified nonphysician health care professionals to report and receive payment for non-face-to-face digital communications that require a clinical decision. Prior to this announcement, audiologists, SLPs, and most other nonphysician groups could not bill Medicare for these services. It is important to note that the e-visits are not considered telepractice services. Here are the key things you need to know right now.
State Medicaid programs and commercial plans may allow audiologists and SLPs to report e-visits, but aren’t required to.
The following information outlines Medicare guidance and policy. State Medicaid agencies and commercial insurance plans have the flexibility to develop their own coverage policies related to e-visit services. Check with your payers directly to ask about coverage and payment for e-visits by audiologists or SLPs. You can direct them to this page for further information about use of these codes.
ASHA confirmed that audiologists may not bill for e-visits to the Medicare program.
In its press release, CMS included SLPs as an example of clinicians who may now report e-visit services, but did not mention audiologists. ASHA reached out to CMS to determine whether audiologists may also report these services for Medicare beneficiaries and strongly urged that CMS provide equal access to these codes for audiologists. However, in subsequent communications with ASHA, CMS staff confirmed that audiologists may not report these services for Medicare beneficiaries, noting that e-visits are outside of the audiology diagnostic benefit category. Check with other non-Medicare payers to determine whether they will cover e-visits provided by audiologists.
The e-visit codes describe specific online communications that require a clinical decision and must meet specific criteria for appropriate billing.
The Medicare G-codes for e-visits are G2061-G2063 and include very specific parameters to determine whether an e-visit can be included on a Medicare Part B (outpatient) claim for payment.
- G2061: Qualified non-physician healthcare professional online assessment and management, for an established patient, for up to seven days, cumulative time during the 7 days; 5–10 minutes
- G2062: Qualified non-physician healthcare professional online assessment and management service, for an established patient, for up to seven days, cumulative time during the 7 days; 11–20 minutes
- G2063: Qualified non-physician qualified healthcare professional assessment and management service, for an established patient, for up to seven days, cumulative time during the 7 days; 21 or more minutes
To correctly report G2061-G2063, the online assessment and management services must be:
- initiated by an established/existing patient,
- conducted through a patient portal,
- medically necessary (requires clinical decision-making and is not for administrative or scheduling purposes), and
- documented and stored to reflect the clinical decision-making and amount of cumulative time spent providing e-visit services to each patient.
Clinicians may report an e-visit code only once per seven consecutive days. Select the appropriate G-code based on the cumulative time spent providing e-visit services to each patient, through a patient portal, over the course of the seven days. Day one of the seven days begins on the first date you provide an e-visit. Telephone calls do not count towards the time for e-visits.
See ASHA’s website for clinical scenarios describing examples of services that could be reported using G2061-G2063.
CMS provides additional guidance on appropriate use of these codes in its March 17, 2020, press release.
Append the modifier GN to indicate services provided by an SLP.
CMS staff confirmed that SLPs should include the GN modifier on claims for e-visits. To append the GN modifier, place it in the “modifier” section of the claim, on the same line as the G-code.
Use the place of service (POS) code that reflects the location of the billing provider.
When entering a POS code on a claim to describe where services occurred, clinicians should use the code that reflects where you provided the service, not where the patient received the service. For example, if a clinician provides the e-visit service from their private practice, enter POS 11 for “office”. Do not enter POS 12 for the patient’s home.
Check directly with your local Medicare Administrative Contractor (MAC) to clarify additional billing and claims processing guidelines.
ASHA provides the following information based on published guidance from CMS and discussions with CMS staff. Contact your local MAC for specific information and guidance related to implementation and payment for e-visit services.
The e-visit codes do not replace other services, such as evaluation and treatment of speech, language, swallowing, or hearing disorders.
The e-visit codes do not represent real-time interactions and do not replace evaluation or treatment services described by existing Current Procedural Terminology (CPT ® American Medical Association) codes. These codes are limited in scope and reflect brief, patient-initiated check-ins or consultations that require clinical decision-making. Do not report these codes for services you would normally report using CPT codes, such as 92523 for a comprehensive speech and language evaluation. Additionally, CMS indicated the e-visits must be conducted via a patient portal, meaning that other forms of real-time or digital communication, such as e-mails outside of a portal, telephone calls, or text messages are not billable with these codes. CMS provided no additional guidance regarding the definition of a patient portal. Clinicians should check with their local MACs directly to verify whether there is flexibility to provide these services without a patient portal.
This is not an expansion of telepractice services.
CMS classifies G2061-G2063 as technology-based communication services, rather than as telepractice services. As a result, CMS has the authority to expand use of the e-visit codes to Medicare providers who are not authorized, by law, to provide telepractice services to Medicare beneficiaries. CMS has not extended telepractice services to audiologists and SLPs at this time. ASHA continues to advocate for expanded telepractice coverage across payers and will provide updates on the webpage on payment and coverage of telepractice services during COVID-19.
You may notify your patients regarding the availability of these services.
Although the patient must initiate the e-visits, clinicians can notify patients that these services are now available and authorized by Medicare. It is also important to note that the patient must verbally consent to the e-visit prior to initiation of services.
Medicare Part B (outpatient) pays for these services through the Medicare Physician Fee Schedule (MPFS).
The following table lists the national Medicare Part B payment rates for the e-visit G-codes. Actual rates will vary slightly depending on your locality. Although CMS waived cost-sharing requirements for telepractice services, the e-visits are still subject to Medicare’s 20% coinsurance payment from the patient because they are not part of the telepractice benefit. The MPFS does not deduct this amount, so the actual payment by Medicare is 20% less than outlined below. You must make reasonable efforts to collect the 20% coinsurance from the Medicare beneficiary.
Attention speech-language pathologists in private practice – Did you miss the Informational Forum NJSHA held on July 15, 2020? Members can log into the Member Center to watch the recorded version where NJSHA President Robynne Kratchman along with members of the Private Practice Committee addressed issues related to returning to office-based services in the time of COVID-19.
New Jersey Division of Consumer Affairs
State of NJ: Department of Human Services, Division of Developmental Disabilities
Please see the information from The NJ Department of Human Services COVID-19 Response related to practitioners providing services in Adult Day Programs and Residential Centers.
- FERPA and COVID-19
- You can find more information at https://www.asha.org/advocacy/state/
- Find information on your state’s Medicaid by program by visiting www.medicaid.gov.
The SIG 18 Coordinating Committee compiled the following list of resources and hyperlinks to them for consideration before engaging in telehealth services.
- Consider the appropriateness of telehealth for meeting the needs of individuals.
- The organization must have a Business Associates Agreement (BAA) with the videoconferencing company.
- A Business Associates Agreement (BAA) is an agreement between your videoconferencing company and your employer that assures that the transmission of information from provider to client and client to provider is encrypted. Encryption is necessary to provide the first level of compliance with HIPAA & FERPA laws. (See ASHA’s Telepractice Practice Portal page for further information on HIPAA & FERPA). Encryption provides the SLP & employer a great assurance of providing client confidentiality.
- HOWEVER, A BAA IS NOT ENOUGH. To ensure that you are providing services that are compliant with HIPAA & FERPA you will need to implement the following:
- a secure location for providing services that is not interrupted (e.g., having others walk into the room where you are providing service)
- remote access to electronic documentation must be considered to protect client privacy and confidentiality at both sites.
- Consult your state’s teacher certification and SLP/AuD licensure laws regarding use of telehealth.
- Verify that you and the client have necessary equipment and internet speed to engage in a videoconference session.
- Verify that someone will be physically present with the client/patient/student who can support your services.
- Verify contact information for the client/patient/student including a phone number, email, physical address and relevant local emergency services.
- ASHA members are encouraged to be informed and to advise stakeholders and other decision-makers on the implementation of telehealth. Additional Resources Can Be Found At:
Information for Education Settings
(March 12, 2020), the U.S. Department of Education released guidance that pertains to serving students with disabilities during the COVID-19 pandemic. In addition, they provided information on FERPA and COVID-19 and the impact of COVID-19 on assessments and accountability under ESSA
The US Department of Education provides guidance letters for a variety of topics, including missed sessions. State and local education agencies can use those guidance letters to inform their advice to IEP teams charged with evaluating the impact of missed sessions on the provision of free appropriate public education (FAPE) for students.
Here are a list of links (including the ones above) that will be included on the ASHA Coronavirus/COVID-19 Updates page:
- Serving students with disabilities during the COVID-19 pandemic (U.S. Department of Education)
- Impact of COVID-19 on assessments and accountability under ESSA (U.S. Department of Education)
- FERPA and COVID-19 (U.S. Department of Education)
- General K-12 COVID-19 information and resources from the U.S. Department of Education
- Protecting Those You Serve, Co-Workers, and Yourself From COVID-19 (ASHA Leader Live blog)
- Fact Sheet: Coverage and Benefits Related to COVID-19 Medicaid and CHIP (Medicaid.gov)
- COVID 19-FAQs for State Medicaid and CHIP Program Agencies (cms.gov)
- ASHA State by State Info: Includes State Department of Education contact info
A new Telepractice Evidence Map has been added to ASHA’s Evidence Maps tool.
NJ DOE Links
US DOE Links
New Jersey Department of Education (NJDOE) COVID-19: Frequently Asked Questions (FAQ) Related to School Emergency Preparedness Plans:
COVID-19: Frequently Asked Questions (FAQ) Related to School Emergency Preparedness Plans, Updated March 13, 2020
US Department of Education Questions & Answers:
Health and Safety:
Infection Control Resources for Audiologists and Speech-Language Pathologists
General Telepractice Guidelines
State Telehealth Laws and Reimbursement Policies
- PPCN Implementation Instructions
- Adult Pain Scale
- General Needs – 12+ target
- General Needs – 24+ targets
- NJ Division of Deaf and Hard of Hearing COVID Communication Card – English and Spanish
- For Patients Recovering at Home – Nutrition and Hydration: Key Weapons in the Fight Against COVID-19 (English)
- For Patients Recovering at Home – Nutrition and Hydration: Key Weapons in the Fight Against COVID-19 (Spanish)
- For Patients Recovering at Home – Nutrition and Hydration: Quick Facts for COVID-19 Patients (English)
- For Patients Recovering at Home – Nutrition and Hydration: Quick Facts for COVID-19 Patients (Spanish)
Tips and Tricks to Minimize the Impact of Hearing Loss During This Time of Physical Distancing
- If you are having trouble understanding what is being said tell the person with whom you are communicating. Good communication is your right!
- Take advantage of telemedicine services that may be available by your audiologist.
- Wash your hands before and after handling your hearing aids or cochlear implant processors. Remember they are close to your eyes and mouth.
- Use a communication card like that available on the NJ Department of Human Services website.
- If possible, ask individuals with whom you are interacting to use a facemask that has a clear window. There are several companies that make these masks (e.g., www.safenclear.com, www.theclearmask.com) Please note that supplies are limited. If you do a quick search of YouTube will find many DIY videos to make clear masks for yourself.
- Use smartphone apps to facilitate communication. There are many available in the Google Play Store or the App Store. As with most smartphone apps, there is a range in quality and price. Many are free. (Review this abbreviated list, derived from a presentation at the Mass Eye and Ear Infirmary.)
- Apps that convert speech to text so that what is being said can be seen by your eyes.
- Apps to allow home hearing tests that allow you to monitor your hearing and provide results that can be shared with your audiologist.
- Apps that can function as limited hearing aids.
- Use YouTube to find tips and tricks to troubleshoot and maybe even fix a simple problem with your hearing aid like wax build-up.
- Consumer devices that function as personal listening devices are available online. They range in price and quality so be sure to verify the return policy of any product you may purchase.
- If you have to go out, be prepared with a statement about your hearing loss, use a communication card. If you plan to use an app practice with it before you enter a challenging communication situation. The Hearing Loss Association of America has many resources on its website that you may find useful.
Remember hearing loss can create social distancing so let’s think about managing COVID-19 by using physical distancing not social distancing.
Impact of COVID-19 on Hearing and on Individuals with Hearing Loss
COVID-19 as a Cause of Hearing Loss?
- Many individuals with hearing loss are at a higher risk of contracting COVID-19 because they are in the age group (over 65) that has been shown to be more susceptible to the virus.
- Individuals in this age group are also more likely to have diabetes, heart disease and hypertension which has also been associated with susceptibility to the effects of the virus.
- COVID-19 affects different people in different ways but there are some common symptoms (e.g., cough, shortness of breath and fever).
- At this point there is not much information regarding the role of COVID-19 as a possible cause of hearing loss.
Impact of COVID-19 on Individuals with Hearing Loss
- Individuals with hearing loss face communication challenges on a daily basis which are exacerbated by the steps that are being taken to “flatten the curve”.
- Sheltering in place for the nearly 48 million Americans is likely to create communication difficulties especially if access to audiology services are limited.
- Broken hearing aids can create a sense of social isolation and loneliness that can cause stress that may weaken the immune system making individuals more susceptible to the effects of COVID-19.
- Use of facemasks and social distancing are major tools used to limit the spread of the virus.
- Typical facemasks that are in use create several problems for people with hearing loss.
- Covering the mouth eliminates the possibility to speech read
- In a recently published an article the authors showed that masks can make speech sound softer and muffled
- Typical facemasks that are in use create several problems for people with hearing loss.
Ideas to Minimize the Impact of COVID-19 on Individuals with Hearing Loss
- Broken hearing aids may be able to be fixed remotely so reach out to an audiologist.
- Use a speech to text app on a smartphone phone to change speech so that it can be read.
- Use a communication card that is available from the NJ Department of Human Services.
NJSHA has partnered with New Jersey-based Denim & Tailor for sales and distribution of a face mask with a clear window. Click here for more information.
NJSHA also recommends regularly checking the CDC website for general guidance at Coronavirus Disease 2019-CDC is closely monitoring the novel coronavirus outbreak
Voices in Numbers!
We rally together for NJ SLPs, AUDs and those we serve.
With your support through membership, we can continue to have a powerful impact on the lives of many!
The information contained on this webpage is accurate to the best of our knowledge as of the date of posting. The web page is informational only and may change without notice at any time. It should not be construed as legal advice. Please consult with an attorney for issues of legal significance.