President Donald Trump announced a dramatic expansion of covered Telehealth services last week for Medicare recipients. So what does that mean for you as Healthcare providers and for Medicare patients?
In the decades that Telemedicine has been in existence, there has been the introduction of more technology for various specialties to participate in this ever-growing sector.
Many healthcare facilities have been poised to offer Telehealth services for medical specialties such as Cardiology, Genetic counseling, Dermatology, Oncology, Obstetrics, Ophthalmology, Psychiatry, Endocrinology, and even dental care. In fact, over 80% of hospitals nationwide are already set up with some form of Telehealth services. Radiology departments nationwide routinely use a form of Telehealth because often the Physician who reads and generates reports of x-ray, ultrasound and CAT scan studies are in a separate location from the hospital where the scan was performed.
In 2019, the first wave of reimbursed Telehealth services for Medicare patients began as an extension of the Affordable Care Act. Guidelines from CMS outlined what is deemed a Virtual Check-In was now covered as a Medicare Part B service (patient Co-pay still required).
Historically, through the Centers of Medicare and Medicaid Services (CMS), Medicare beneficiaries have imposed strict restrictions on Telehealth services reimbursement. In light of the Coronavirus Pandemic, On March 17, 2020, President Trump announced that previously non-covered telehealth services like phone calls with doctors and videoconferences are now covered. The move provides flexibility for patients concerned about coming into contact with others who could spread the virus.
CMS Administrator Seema Verma said during the briefing that Medicare beneficiaries who were previously limited to telehealth services based on their location “will be able to receive a wide range of services via telehealth without ever having to leave home.
Under the Coronavirus Preparedness and Response Supplemental Appropriations Act, the 1135 waiver has been activated by CMS emergently and the provisions will be temporary. The waiver is two fold in expanding access to Medicare patient’s medical providers while simultaneously limiting the need for travel to a healthcare facility. Beginning on March 6, 2020 Medicarel now covers office, hospital or patient residence visits provided by Telehealth modalities. What is important for physicians who are not already utilizing a Telehealth platform is understanding the different capabilities and how they are classified by CMS.
Per CMS there are 3 types of Telemedicine Services . Medicare Telehealth Visits, Virtual Check-In and E Visits.
Medicare Telehealth Visits are where the Medical Provider uses real-time interactive audio and video telecommunications. Readily available phone apps such as Face-Time or Duo and computer apps as Skype are also being approved during this time. Regulations regarding HIPPA violations are also being waived to further encourage their use for patient care. For more sophisticated platforms that combine interactive audio and video, secure messaging and clinical file sharing there are a myriad of programs such as the free app Doxy.me which can tier the services you want or subscription services such as DrFirst available to clinicians with rapid on-boarding. With the new provision, Medicare Telehealth Visits can be billed by the provider at the same rate as an in-person visit, and is allowing new patients to be seen by this method as well.
Virtual Check-Ins are for providers who are using either a Telemedicine platform or conduct simple 5-10 minute phone calls with established Medicare patients. Patients also have the option to record and forward messages or images to their Medical Provider that upon review can also be billed. Providers may now respond via text, email, Telemedicine platform or patient portal. These services are covered under the Medicare Part B rate with no additional co-pay required from the patient.
E-Visits are generated when established patients use their Medical Provider’s online Patient Portal for a non-face to face communication. Medicare Part B coinsurance and deductible would apply to these services.
Because Medicare patients have not been contacted by Medicare directly as of yet, regarding these new benefits, patients are unsure how to best take advantage of this regulation especially in the light of ever changing local government’s plans to Shelter-in-Place. This lack of cohesion has forced many patients to go directly to sites such as Teladoc Health, Amwell, PlushCare, Doctor on Demand and MD Live for virtual visits. Unfortunately, these sites are being overwhelmed and users are
For those physicians and practices trying to implement Telehealth quickly, The American Medical Association has created a quick start up guide.
Getting Started (from AMA Start Up Guide):
- Check with your malpractice insurance carrier to ensure your policy covers Telemedicine
- Reach out to your State Medical Association/Society for guidance on vendor selection, evaluation and EHR contracting.
- Set up a well trained team to help facilitate the rapid on-boarding of the Telemedicine services
- Review your State’s policies on the rules and regulations regarding the use of Telemedicine and if there will be any conflict with billing, after this emergent phase has passed
- During this crisis with Medicare Telehealth visits, new patients can be seen. CMS has issued the following waiver for Medicare patients: “Temporarily waive requirements that out-of-state providers be licensed in the state where they are providing services when they are licensed in another state. Medicaid waivers must be requested by the individual state that wants to use them.
- The Federation of State Medical Boards is tracking executive orders related to licensure. Stay up to date: http://www.fsmb.org/advocacy/covid-19/
Click here for the full AMA quick guide to Telemedicine in practice – the guide gives instruction on getting started; policy, coding and payment; practice implementation; and links to other helpful resources.
The CMS Fact Sheet explains how expanded Medicare coverage for Telehealth enables beneficiaries to receive a wider range of health care services.
Last, review the Best Practices for Telehealth Documentation Requirements. As we all know, if it is not written in the Medical Records, it didn’t happen. Many platforms will have a template to meet CMS standards, but if you want to get started prior to any on-boarding, make sure the salient points are covered:
- Need for Telemedicine Services
- Mode of Transmission
- Time Service Started
- Time Service Ended
- Where is the patient located
- Where is the Provider located
Now is the time to adapt with the rest of the Healthcare system to quick changes in policy and procedure to provide the best care possible for all patients.