The healthcare industry will collectively look back on the COVID-19 pandemic as the catalyst for telemedicine finally coming into its own as a viable care delivery model—and in just a matter of weeks at that.
The pursuit of efficiency in medicine had begun to elevate telehealth long before COVID-19. It’s convenient and offers benefits to providers, payers, and patients alike. Its applications keep growing: disaster medicine situations, growing populations of rural and underserved patients, the elderly or those with disabilities lacking transportation, those with chronic conditions requiring regular health checks—all benefit from telehealth and help hospitals’ and payers expand their reach to patients far and wide.
It’s not surprising, then, that many of the largest nationwide health plans (e.g., UnitedHealth, Anthem, Cigna, Aetna, Humana) have expanded coverage and reimbursement for telehealth services and are investing heavily in marketing them.
Commercial and government payers can expect to continue adding to their panels more and different types of clinicians who provide telehealth services, in order to satisfy fast-growing patient demand. Healthcare organizations must keep pace while minimizing the time it takes to receive reimbursement.
Even before COVID-19, a positive trajectory for telemedicine
As state governors issued stay-at-home orders starting in March 2020 to help prevent the spread of the disease, the Centers for Medicare & Medicaid Services (CMS) was busily loosening regulations around telemedicine in response to the COVID-19 pandemic. The goal: to prepare hospitals, healthcare systems, practitioners, and staff to meet patient needs during the public health emergency.
CMS broadened access to telehealth services so that beneficiaries can receive a wider range of services from practitioners without having to travel to a healthcare facility. Specifically, the temporary and emergency benefits provided fall under the 1135 waiver authority and Coronavirus Preparedness and Response Supplemental Appropriations Act.
The changes, albeit temporary, amounted to an immediate boost for telehealth, in particular helping to surmount three factors that previously had held back telemedicine from reaching its true potential:
- Which providers were allowed to administer telemedicine, associated primarily with state licensure laws, and healthcare practitioners’ facility-based credentials and clinical privileges.
- How they could deliver it, associated with factors including provider and patient location.
- How it would be covered and paid for by health plans, associated with reimbursement and medical coding.
The temporary regulatory waivers, among other items, allow Medicare coverage of and reimbursement for telehealth nationwide including in patients’ homes, delivered by physicians, nurse practitioners, clinical psychologists, and licensed clinical social workers. Previously, telehealth was reimbursed only when the person receiving the service lived in a designated rural area and when they left their home to visit a clinic, hospital, or certain other types of medical facilities for the service.
CMS is also waiving the provisions related to telemedicine for hospitals and critical access hospital (CAHs) at 42 CFR 482.12(a)(8-9) and 42 CFR 485.616(c), easing the delivery of telemedicine services to a hospital’s patients through an agreement with an offsite hospital, increasing access to necessary care for hospital and CAH patients (including specialty care).
It’s notable that CMS had already begun reimbursing for virtual check-ins (brief patient-initiated communications with a healthcare provider) and e-visits (non-face-to-face patient-initiated communications through an online patient portal) in 2019. But the 1135 waiver enables Medicare beneficiaries to receive specified telehealth services such as evaluation and management, mental health counseling, and preventive health screenings.
General telehealth takeaways resulting from COVID-19
During the COVID-19 public health emergency, for telehealth services:
- States are modifying licensure requirements and renewals for physicians in response to COVID-19. (Federation of State Medical Boards)
- States are modifying in-state licensure requirements for telehealth in response to COVID-19. (Federation of State Medical Boards)
- Medicare will more broadly pay for telehealth services to patients during the public health emergency. Some 85 telehealth services were added to the list of Medicare-covered services. The telehealth visits are considered the same as in-person visits and are paid at the same rate. (Centers for Medicare & Medicaid Services)
- Starting March 6, 2020 and for the duration of the COVID-19 public health emergency, Medicare will make payment for professional services furnished to beneficiaries in all areas of the country in all settings. (Centers for Medicare & Medicaid Services)
- Regarding the Health Insurance Portability and Accountability Act (HIPAA), the HHS Office for Civil Rights will exercise enforcement discretion and waive penalties for HIPAA violations against providers that serve patients in good faith through common communications technologies (e.g., FaceTime or Skype), during the COVID-19 nationwide public health emergency. (Office of the Inspector General)
As policy changes around telehealth develop rapidly, there are four key areas to watch:
- Cross-state licensing and the Interstate Medical Licensure Compact. It established a voluntary expedited pathway to licensure for qualified physicians to practice in multiple states.
- Prescribing medications via telehealth. Opioid and other prescription medication addictions have made prescribing laws an ever-evolving facet of telemedicine.
- What constitutes the establishment of a patient-physician relationship. All 50 states allow the relationship to be formed via telehealth, but technology type varies by state.
- Whether the state requires written patient informed consent. CMS doesn’t require it, but state guidelines vary. At issue: patient confidentiality, privacy, the technology needed at home for a virtual visit, and expectations for telehealth scheduling and billing.
It remains to be seen whether long-term, permanent changes will be made to telehealth oversight based on the responses by patients, provider organizations, and payers when it became a vital—and for some the only—care delivery mode during the COVID-19 pandemic.
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