Telehealth and Telemedicine Accelerate into the Mainstream


Expanded Medicare telehealth coverage was released by the Trump administration in early 2020. It enabled beneficiaries to receive a wider range of healthcare services from their doctors without having to travel to a healthcare facility. Medicare, which is administered by the Centers for Medicare and Medicaid Services (CMS), would start temporarily paying clinicians to provide telehealth services for beneficiaries residing across the country.

Here, we’ll explore the evolution of telehealth and telemedicine from being covered as an emergency measure toward going mainstream and sought-after on all fronts.

What Was Initially Included in Telehealth Expansion

On March 13, 2020, President Trump announced an emergency declaration under the Stafford Act and the National Emergencies Act. Consistent with President Trump’s emergency declaration, CMS expanded Medicare’s telehealth benefits under the 1135 waiver authority and the Coronavirus Preparedness and Response Supplemental Appropriations Act. This guidance and other actions by CMS provided regulatory flexibility to ensure all Americans, including high-risk individuals, were aware of easy-to-use, accessible benefits while helping to contain the spread of coronavirus disease 2019 (COVID-19).

A range of healthcare providers such as doctors, nurse practitioners, physician assistants, clinical psychologists, and licensed clinical social workers were then able to offer telehealth to Medicare beneficiaries. Beneficiaries could receive telehealth services in any healthcare facility, including a physician’s office, hospital, nursing home or rural health clinic, as well as from their homes. Services they could receive included:

  • Common office visits
  • Mental health counseling
  • Preventive health screenings

How the CARES Act Affected Telehealth Services

On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security Act (CARES Act)was signed into law. Section 3704 of the CARES Act authorizes rural health clinics (RHCs) and Federal Qualified Health Centers (FQHCs) to furnish distant site telehealth services to Medicare beneficiaries during the COVID-19 Public Health Emergency (PHE). Medicare telehealth services generally require an interactive audio and video telecommunications system that permits real-time communication between the practitioner and the patient. Rural health clinics and Federal Qualified health centers with this capability could immediately provide and be paid for telehealth services to patients covered by Medicare for the duration of the COVID-19 Public Health Emergency.

Any health care practitioner working for the rural health clinic or the Federal Qualified health center could provide distant-site telehealth services within their scope of practice. Practitioners could furnish distant-site telehealth services from any location, including their home, during the time they worked for the rural health clinic or Federal Qualified health center. Providers could furnish any telehealth service that Is listed on the telehealth services list.

As health systems work to meet demand for telehealth services, there are so many factors to consider that cybersecurity concerns can easily fall behind. However, cybersecurity shouldn’t just be on the top of the list, it should be a key action item.

Rural Health Clinics and Telehealth

The CARES Act authorized rural health clinics to furnish telehealth services and bill as the distant site provider during the COVID-19 Public Health Emergency. Providers could perform these services from any location, including their home, during times when they would have otherwise been regularly scheduled to see patients in the rural health clinic.

Rural health clinics were and are allowed to furnish any telehealth service that is approved by Medicare on the telehealth service list and includes telephone services.

  • Audio-only telephone E/M service codes 99441, 99442 and 99443 are now covered
  • Bill with HCPCS G2025
  • Reimbursement will be AIR amount through July 1 when claims will automatically be reprocessed by the MAC and reprocessed at the $92.03 rate.
  • Must provide at least five minutes of telephone E/M.
  • Call cannot be related to an E/M service provided within the previous seven days or lead to an E/M service or procedure within the next 24 hours or soonest available appointment.

CMS issued the guidelines to enable the billing for these services, which required changes to rural health clinics’ existing processes. Facilities needed to:

  • Set up the billing for the services appropriately
  • Manage the reprocessing of the claims
  • Ensure appropriate handling of the secondary insurances and refunds made as applicable
  • Estimate due to/due from for the payment differential
  • Establish tracking for cost reporting purposes

The CARES Act allowed this provision of care to further maintain the safety of the patient and the healthcare provider. It does not come without its challenges and complexities with coding, billing, cost reporting and accounting. This further supports the establishment of well-documented policies and procedures on how an organization addresses the Rural Health Clinic Telehealth service implementation.

Since the telehealth services rendered by rural health clinic practitioners will not be paid the all-inclusive rate (AIR) but on a blended-fee schedule amount, the associated costs of furnishing the telehealth services are not used in calculating the AIR on the Medicare cost report.

  • Rural health clinics should appropriately track the costs of providing both originating and distant site telehealth services in order to properly report these services on the Medicare cost report.
  • In addition, we recommend tracking the time spent providing distant site telehealth services in order to exclude these hours from the calculation of the FTE when calculating the productivity standards.

Policy and Payment for Telehealth/Telemedicine Services

The policy and payment landscape around telehealth and telemedicine remains complex; however, as the country continues to navigate this pandemic, these services have been rapidly expanded.

Ensure you are providing services in accordance with your state laws and regulations. As part of emergency declarations, many governors have relaxed state laws and regulations related to the provision of telemedicine services.

Licensure is also an important item to consider. If you are licensed in the state where the patient is located, there are no additional requirements. If you are not licensed in the state where the patient is located:

  • CMS issued the following waiver for Medicarepatients: 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. Medicaidwaivers must be requested by the individual state that wants to use them.
  • Many governors have relaxed licensure requirements related to physicians licensed in another state and retired or clinically inactive physicians. You must contact your state board of medicine or department of health for up-to-the-minute information.

Increased usage of telehealth and telemedicine is just one way health systems can begin to transform their operations. With a digital first approach, you can set your organization up for stability and strength in the next stage.

How Telehealth Will Continue in the Wake of COVID-19

The expanded use of telehealth and telemedicine has been critical during the coronavirus pandemic. Patients have been able to communicate with their doctor without visiting their doctor’s office, driving down the spread of the virus. This mode of care will likely remain popular and in-demand after the COVID-19 Public Health Emergency ceases.

Even before the COVID-19 Public Health Emergency, telehealth and telemedicine were on the rise. The American Medical Association’s Digital Health Study found that telehealth and telemedicine had doubled from 14 percent to 28 percent in 2019 from the previous study in 2016.

In December 2020, CMS released their final Physician Fee Schedule (PFS) for 2021, updating, adjusting and clarifying policies and provisions. This PFS notes more than 60 telehealth services which will remain permanent after the COVID-19 Public Health Emergency, and CMS announced that they will continue seeking opportunities to expand such care. Additionally, U.S. representatives have introduced a bill that would extend telehealth access after the COVID-19 PHE, Protecting Access to Post-COVID-19 Telehealth Act of 2021.

On July 13, 2021, the Centers for Medicare & Medicaid Services (CMS) issued a proposed rule for Medicare payments under the Physician Fee Schedule (PFS), and other Medicare Part B issues, which would be effective January 1, 2022. As CMS continues to evaluate the temporary expansion of telehealth services that were added to the telehealth list during the COVID-19 PHE, CMS is proposing to allow certain services added to the Medicare telehealth list to remain on the list to the end of December 31, 2023, so that there is a glide path to evaluate whether the services should be permanently added to the telehealth list following the COVID-19 PHE. In the area of mental health services, CMS is evaluating frequency of required in person visits and whether it would be appropriate for audio-only communication technology when used for telehealth services for the diagnosis, evaluation, or treatment of mental health disorders furnished to established patients in their homes.

Best Practices for Telehealth Services

Since telehealth and telemedicine are due to stay in-demand and even preferable for many patients, healthcare organizations should prepare for its permanent place in their operations. Whether you run a small local medical practice or a major hospital, there are great benefits to shoring up these services and making them as convenient, accessible and quality as possible. Here are a few must-haves for any provider offering telehealth services:

  • Ensure patients understand how to access telehealth visits based on your practice’s technology and workflow.
  • Ensure communication over telehealth coverage with payor who has highest percent of your patient population.
  • Have a designated space in your practice to accommodate telehealth visits.
  • Ensure you are still properly documenting these visits, preferably in your existing EHR, as you normally would with an in-person visit.
  • Ensure you receive advanced consent from patients for telemedicine interactions.
  • Ensure patients know your practice offers telehealth services.
  • Update your cybersecurity policies, procedures and trainings to account for added risks of telehealth.

Are you interested in improving this, or any other, aspect of your operations? At Eide Bailly, our experts have decades of experience working with health systems on some of their toughest challenges. We understand the nuances of the healthcare industry and can help you navigate to a position of strength and certainty amid change.

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