Contact: Kathy Rhoad Director of Public Relations & Program Development
ORANGEBURG, SC—The Federal Communications Commission (FCC) has notified Palmetto Care Connections (PCC) that PCC’s broadband consortium members will receive more than $17 million in broadband subsidies for the period of 2019 through 2022. These funds represent actual savings for health care providers.
“As the leader of the South Carolina broadband consortium, PCC helps health care providers receive broadband savings through the FCC’s Healthcare Connect Fund Program by assisting them with the internet service provider bidding process and filing the appropriate information, invoices and supporting documentation to the Universal Service Administration Company (USAC),” said South Carolina Office of Rural Health Chief Executive Officer Graham Adams, Ph.D. “PCC has a proven track record as a top health care broadband consortium leader in the nation.”
“The Healthcare Connect Fund Program provides subsidy reimbursements for up to 65% of eligible broadband expenses for eligible health care providers,” said PCC Director of Information Technology Matt Hiatt. “Currently, PCC files for over 1200 circuits across more than 100 health care organizations that are approved for federal subsidies. Our consortium members are located in five states in addition to S.C., and the number of members continues to grow each year.”
South Carolina broadband consortium members include federally qualified health centers, nonprofit hospitals, behavioral health centers, rural health clinics, teaching hospitals, rural emergency departments, skilled nursing facilities and area health education centers.
“The broadband subsidies have provided funds that have allowed many organizations to reinvest in their technology systems and telehealth which ultimately has led to better patient care,” said Hiatt.
CareSouth Carolina Chief Information Officer Gary Herrington agrees. “CareSouth Carolina has been a member of the PCC broadband consortium for many, many years. Thanks in large part to the reimbursements from the Healthcare Connect Fund Program, we have had the ability to grow our information technology infrastructure to meet the needs of CareSouth’s more than 38,000 patients and 500 employees at 14 rural medical practices in South Carolina’s Pee Dee region.”
Another PCC broadband consortium representative, Prisma Health Senior Vice President and Chief Information Officer Rich Rogers said, “Prisma Health has valued our collaborative partnership with Palmetto Care Connections for several years. We have been on a common journey to extend virtual health capabilities to underserved communities across South Carolina. The benefits of this relationship were evident in 2020 as we have been able to extend necessary health care services during a time of greatest need.”
“PCC did not start out working in the broadband area,” said PCC Chief Executive Officer Kathy Schwarting. “As we were trying to expand telehealth in rural communities, we found that one of our largest barriers is broadband access. You cannot have a good telehealth visit if you do not have adequate broadband. Through the Healthcare Connect Fund Program, PCC has helped make broadband more affordable for health care providers across S.C. As a result, providers were prepared to use telehealth to respond to challenges of the COVID-19 pandemic.”
Since 2013, PCC has helped health care providers save more than $25 million in broadband costs through the FCC’s Healthcare Connect Fund program.
Established in 2010, PCC is a non-profit organization that provides technology, broadband, and telehealth support services to health care providers in rural and underserved areas in S.C. PCC hosts the Annual Telehealth Summit of South Carolina presenting state and national best practices and trends, as well as providing networking connections for health care, information technology and broadband professionals. PCC co-chairs the South Carolina Telehealth Alliance, along with the Medical University of South Carolina, serving as an advocate for rural providers and partnering with organizations to improve health care access and delivery for all South Carolinians.
As the new year begins and the nation looks to tackle COVID-19 and move on, telehealth will be front and center in a lot of conversations from the halls of Congress to the patient’s home.
January 25, 2021 – Telehealth policy and new methods for connected care will figure prominently in healthcare during 2021, and Xtelligent Healthcare Media will be there to explore it.
In a special edition of our Healthcare Strategies podcast series, Xtelligent Healthcare Media’s editors laid out their plans for covering the topics and trends of the year ahead. As expected, much of the focus will be on the nation’s – and the world’s – continuing battle with the coronavirus pandemic, and how new President Joseph Biden and his administration will handle it, moving from reaction to vaccination to recovery.
At mHealthIntelligence.com, the focus will be on how the healthcare and payer industries are using telehealth to deal with the pandemic, and how that will affect the playing field once this public health crisis has been contained.
Listen to the full podcast to hear more details. And don’t forget to subscribe on iTunes, Spotify, or Google Podcasts.
From large health systems to solo practices, many providers jumped on the telehealth bandwagon in early 2020 to address the pandemic and shift from in-person care to virtual care. They were helped by federal and state emergency measures aimed at easing access to telehealth and improving coverage so that they’d be paid for using the technology.
Those measures, however, will end when the public health crisis does – whether that’s this year or next. As a result, providers are hesitant to embrace a long-term strategy because they don’t know what the rules will look like then. Some states have moved to make the emergency measures permanent, but many others are waiting on the federal government to act. And Congress has a lot on its mind right now.
Early actions, from the Centers for Medicare & Medicaid Services’ 2021 Physician Fee Schedule to the latest economic relief package, offered mixed results. A few tidbits here and there will help advance telehealth adoption, but telehealth advocates are so far disappointed with what they’ve seen coming out of Washington.
One positive note might be in the government’s efforts to tackle broadband accessibility, long considered one of the biggest barriers to telehealth expansion in underserved and rural communities. As evidenced by the Federal Communications Commission’s COVID-19 Telehealth Program and Connected Care Pilot, the government is support hundreds of programs across the country that are improving broadband coverage to expand telehealth platforms.
In other topics, the year ahead will see a lot of action in the mHealth market, particularly around devices, clothing and smart gadgets in the home that aim to collect health and wellness data and give patients and platform to communicate with their care providers. The consumer-facing health and wellness market – think Fitbit, Apple Watch and Nest, just to name a few – has been inching its way into healthcare for years, just waiting for payers and providers to trust their clinical value. COVID-19 may help that along.
And we’ll likely see a lot of activity around two fast-growing connected health platforms, asynchronous (store-and-forward) telehealth and remote patient monitoring, both of which are seeing a lot of innovation and use in the COVID-19 era. Asynchronous telehealth has been used over the past few years for direct-to-consumer services, most often non-acute issues that clog up waiting rooms and which could be addressed at home. A platform that allows patients and providers to log on and submit data on their own schedule – without need of a video connection – has its benefits.
And RPM will see a lot of use as health systems look to push patient care out of the hospital and into the home, and as CMS recognizes the value of the home in patient care. The focus now may be on treating COVID-19 patients at home, but expect to see a lot of growth in the use of RPM for chronic care management, post-discharge recovery and rehab, to name a few.
The Protecting Access to Post-COVID-19 Telehealth Act of 2021 includes broadly popular provisions such as eliminating geographic and originating site restrictions.
A bipartisan group of U.S. representatives has reintroduced a bill aimed at expanding access to telehealth beyond the COVID-19 pandemic.
The Protecting Access to Post-COVID-19 Telehealth Act of 2021 legislation was introduced this past week by Rep. Mike Thompson, D-Calif., cosponsored by Reps. Peter Welch, D-Vt., Bill Johnson, R-Ohio, David Schweikert, R-Ariz., John Curtis, R-Utah; and Doris Matsui, D-Calif.
“Telehealth has played a major role in keeping vulnerable patients safe during this pandemic, and this bipartisan legislation keeps telehealth expansion in place,” said Johnson in a statement.
“Increasing access to telehealth has long been a priority of mine, and I encourage my colleagues to support this important bill; it’s time for Congress to make telehealth expansion and access permanent,” he added.
WHY IT MATTERS
The bill, which was first introduced in July 2020, would help safeguard access to virtual care after COVID-19 via four main provisions. According to a press statement from Thompson’s office, it would:
Eliminate most geographic and originating site restrictions on the use of telehealth in Medicare and establishing the patient’s home as an eligible distant site.
Authorize the Centers for Medicare and Medicaid Service to continue reimbursement for telehealth for 90 days beyond the end of the public health emergency.
Make permanent the disaster waiver authority, enabling Health and Human Service to expand telehealth in Medicare during all future emergencies and disasters.
Require a study on the use of telehealth during COVID, including its costs, uptake rates, measurable health outcomes, and racial and geographic disparities.
“This unprecedented pandemic has proven that telehealth not only works, but that it’s essential,” said Welch.
“These practical telehealth provisions have been successfully implemented and should be continued to ensure that everyone has access to quality healthcare, no matter where they live or how mobile they are. This is a common-sense step to make sure our policies keep pace with our technology,” he added.
Advocates praised the bill’s reintroduction, noting that it would allow older adults to continue accessing a wide range of medical care.
“For decades, the Medicare statute has severely limited telehealth services, while other payers increasingly relied on telehealth to provide care to patients when and where they need it,” said Ann Mond Johnson, CEO of the American Telemedicine Association, in a statement. “This disparity has become shockingly clear during the COVID-19 pandemic, when in-person care has not been an option for most patients.
“While Congress and the Centers for Medicare and Medicaid Services acted quickly to implement waivers to allow for the reimbursement of telehealth services during the COVID19 public health emergency,” she added, “older adults will lose access to this important care unless Congress again takes decisive action.”
THE LARGER TREND
The widely applauded earlier version of this bill was greeted with praise and enthusiasm from a wide range of industry groups, who hailed it as an effort to keep patients from falling off a telemedicine “cliff” after the pandemic.
But despite the excitement, the bill’s momentum ground to a halt in July after being referred to committee.
“Telehealth has been a game-changer during the coronavirus pandemic, ensuring that patients can continue to get care, while reducing the spread of the virus during routine medical visits,” said Thompson.
“However, patients could face an abrupt end to the practice once the pandemic is over, even though it’s long been a proven and cost-effective way to get care.”
Some will say 2020 was the year that everything changed, but in reality, it will be 2021 that determines our new healthcare reality. Virtual care advanced quickly—and under duress—last year. How will we learn from the seismic shifts in care delivery we experienced thanks to COVID-19? How can we help providers and innovators embrace the transformation? How will we solidify these gains?
Dad’s Story: Telemedicine Pioneer
We think of telemedicine as a relatively recent invention—only made possible by the internet and smart phones—but I had my first taste of it 60 years ago. As a physician who was trained in the importance of placing your hands on a patient to diagnose and heal—I have become an ardent advocate for telemedicine after decades of seeing it improve care.
My earliest experience was with my own physician-father. When I was a young boy about 8 or 9 years old, the telephone would ring in my parent’s bedroom in the middle of the night three to four times a week. Dad was trained in what was then still the young specialty of cardiology. As one of our region’s few cardiologists, providers in rural Tennessee relied on his expertise. Each time the phone would ring, Dad would calmly speak with a nurse or a doctor, and after learning the patient’s symptoms, would place the receiver on a clunky, antiquated device on his bedside table that would read out the little blips of an EKG machine on a continuous strip of paper. Dad would look at that EKG to make a diagnosis and instruct a course of treatment. He was on the pioneering front of using telemedicine, using remote technology and monitoring, to connect to patients all over the middle third of the state.
Years later in the 1980s, I relied on telemedicine in my own practice as a heart transplant surgeon to manage the chronic immunosuppressive care of my heart recipients all over the country for months after their transplants. And as the only doctor in the Senate in the 1990s, I spearheaded major investments in programs establishing expensive T1 lines to Native Americans on reservations which allowed us to provide real-time telehealth to vulnerable populations in remote areas.
Today, as a partner and board member, I am heavily involved with Teladoc Health, Livongo, and a virtual dental care company, Smile Direct Club. In my 60-year journey with telemedicine, I have never been more optimistic about our future as I am today.
We are at an inflection point. The sheer scaling of telehealth services that took place across the country over the course of the pandemic has been astounding. The explosion of virtual care is the single most transformative—and most constructive—advancement to emerge from the COVID-19 crisis.
Providers and health systems have tirelessly stepped up to the challenge of adopting and proactively engaging patients in virtual care:
Pittsburgh’s UPMC saw video visits, which were averaging 20-30 a day pre-pandemic, grow to 6,000 a day at the pandemic’s height.
Kaiser Permanente—which already had a relatively large telehealth presence with about 15% of scheduled outpatient visits conducted virtually—saw that figure skyrocket to 80% in the early spring.
The Centers for Medicare and Medicaid Services (CMS) shared that between mid-March and mid-October over 24.5 million out of 63 million Medicare enrollees—more than a third—received a telemedicine service.
And we at Teladoc Health have seen utilization stabilizing at a level 40% higher than before COVID.
This is a seismic shift in the culture of telehealth. The culture of doubt, of fears around privacy, of inadequate reimbursement, of the unknown, was replaced by a culture of confidence and trust, a culture which values convenience, affordability, and rapid access to quality care. All this in the safe environment of home, eliminating the risk of COVID spread.
With this change, providers are increasingly comfortable conducting virtual visits and are seeing the benefits. A recent American Medical Association survey of nearly 1,600 physicians and other health professionals found that 60% reported that telehealth has improved the health of their patients and 80% indicated it had improved the timeliness of care.
Similarly, Americans are increasingly at ease with virtual visits, with one recent HIMSS survey showing 77% of consumers willing to use some form of telehealth post-COVID, and 41% preferring it.
This cultural acceptance is already greatly enhancing mental and behavioral health access, substantially improving patient convenience and experience, increasing patient adherence, and expanding reach to regions with provider shortages.
How, then, do we preserve and expand the gains made when this public health emergency comes to an end?
How Policy Has Shaped and Will Continue to Shape Virtual Care
We must recognize that the rapid progress was made possible by emergency regulatory measures that speeded access and reimbursement for telehealth services, making physician adoption feasible, and removing traditional bottlenecks in administrative decision-making.
Medicare offered payment parity and waived geographic restrictions. Medicaid expanded coverage, including coverage of audio-only care.
CMS added 144 additional services that could be furnished via telehealth and relaxed physician interstate licensure, waiving Medicare and Medicaid’s requirements that practitioners be licensed in the state where they are providing services. And HIPAA data privacy rules were relaxed, allowing providers to use non-HIPAA compliant telehealth platforms, like FaceTime and Skype.
Importantly, private insurers followed the federal government’s lead, waiving cost-sharing and expanding telemedicine programs.
The Centers for Medicare and Medicaid Services, the Administration, and the private sector should be commended for responding so quickly and so comprehensively to meet the rapidly changing needs of our healthcare communities during the pandemic.
But now we must make these gains permanent.
Many of my former Congressional colleagues—Democrat and Republican—are in favor of doing just that. Some needed policies were included in the year-end spending and COVID-19 relief package. Funding was increased for the Federal Communications Commission’s telehealth work and expansion of broadband, and Medicare expanded coverage for telemental health services.
But I agree with American Telemedicine Association President Ann Mond Johnson: “The noticeable lack of permanent reform or a guaranteed extension of the telehealth flexibilities in this relief package is disheartening for the millions of Americans who relied on telehealth to access care, and our healthcare providers still on the frontlines of the pandemic. We believe arbitrary restrictions on telehealth must be permanently removed to make way for a modernized and more accessible healthcare system.”
I served 9 months in an equally split, 50 to 50, Senate. With a razor-thin Democratic majority in the Senate that is subject to filibuster, I’m frequently asked where we might see bipartisan agreement in health policy in 2021. Telehealth is unquestionably at the top of that list.
To continue this progress, we need to permanently allow telehealth access regardless of patient and provider location and codify the broader range of practitioners including physical therapists, occupational therapists, and speech language pathologists to provide Medicare telehealth services. Congress should also address cross-state licensing barriers, though this will be a more challenging area to navigate.
Federally Qualified Health Centers and Rural Health Clinics—community-based health care providers that support underserved populations—should be authorized to continue to offer telehealth after COVID and reimburse all forms of communication equally if providers can meet the same standards of care.
While the Administration has done a good job, there is a risk that broad telehealth deployment—if not carefully designed—could replicate the barriers of the traditional bricks and mortar health system that produce disparities.
One glaring example is a bias in some of the new authorizations for two-way video communications. If we discriminate against telephone (without video) users, for example, we will leave behind rural communities without access to broadband, as well as minority and other lower-income populations that may not have more expensive smart phones with two-way video capabilities.
Finally, while I believe most regulatory changes made to advance telehealth and virtual care during these extraordinary times should be made permanent, parity in payment is one that should be revisited following the crisis. Undoubtedly, payment parity was necessary to motivate physician participation. But since many overhead costs are eliminated in virtual transactions and thus result in overall cost savings, these savings should flow to the patient as well as the provider.
To reiterate, we are at an inflection point. And inflections bring new challenges, and inflections demand changed perspectives—changed understanding, and changed behaviors on our parts. We have the opportunity to embrace these changes and unleash an exciting new frontier of virtual care, with the public sector reimagining regulatory guidelines to allow private sector innovation to rise to meet patient demand and improve care for all.
This op-ed is based on remarks I delivered on January 12, 2021 at the American Telemedicine Association EDGE Policy Conference. A video of the full remarks is available online.
CMS just issued a correction to its guidance on 2021 Medicare rules for remote physiologic monitoring (RPM) services. The correction is effective January 1, 2021 and revises the preamble commentary in the Medicare Physician Fee Schedule Final Rule, previously published on December 1, 2020. It adds language that was inadvertently deleted from the Final Rule, summarizing and responding some public comments. Here is a summary of the new changes:
20 Minutes of Time Includes, but Not Limited to, “Interactive Communication” with Patient
The required 20 minutes of time associated with CPT codes 99457 and 99458 includes care management services, as well as synchronous, real-time interactions with the patient. CMS clarified the “interactive communication” element contributes to the total time, but is not the only activity that can be included when calculating the 20 minutes per month. Put another way, the 20-minutes of intra-service work associated with CPT codes 99457 and 99458 includes a practitioner’s time engaged in “interactive communication” as well as time engaged in non-face-to-face care management services during the month. This clarification reverses the commentary in the Physician Fee Schedule Final Rule, but is consistent with the statements in CMS’ associated Fact Sheet published the same day.
RPM Billing by One Practitioner, Per Patient, Per Period
Only one practitioner can bill CPT codes 99453 and 99454 during a 30-day period and only when at least 16 days of data have been collected on at least one medical device. “Even when multiple medical devices are provided to a patient,” CMS explained, “the services associated with all the medical devices can be billed by only one practitioner, only once per patient, per 30-day period, and only when at least 16 days of data have been collected.” Of course, the services must also be reasonable and necessary in order to be reimbursed under the Medicare Program.
Know Your Remote Monitoring Codes
CMS reminded practitioners the universe of RPM-related codes is not limited to just CPT codes 99091, 99453, 9454, 94557, and 99458. There are additional, more specific codes available for billing that allow remote monitoring (for example, CPT code 95250 for continuous glucose monitoring and CPT codes 99473 and 99474 for self-measured blood pressure monitoring). When a more specific code is available to describe a service, the CPT Handbook dictates that the more specific code should be billed. Remote monitoring can often have two facets. The first part is collecting and monitoring the data, whereas the second part is treatment/ management services of the conditions monitored with the data. Practitioners should consult with their certified billing and coding professionals to help ensure accurate coding and claim submission.
For more information on telemedicine, telehealth, virtual care, remote patient monitoring, digital health, and other health innovations, including the team, publications, and representative experience, visit Foley’s Telemedicine & Digital Health Industry Team Page.
The COVID-19 pandemic has placed renewed focus on the United States’ insurance-based health care system. In March 2020, the largest U.S. health insurers announced that they would waive cost-sharing obligations for COVID-19 tests and treatment, including for telehealth visits. This signaled a different approach from America’s health insurance industry in combating the spread of the virus. What followed was a series of temporary and, in some cases, permanent changes to payer’s telehealth coverage policies. CCHP staff analyzed coverage policies and bulletins for the largest U.S. private payers and summarized the findings in a new report, Private Payer Telehealth Coverage During the COVID-19 Pandemic.
The report builds on CCHP’s COVID-19 research and resources by detailing the efforts that major U.S. health insurance carriers took to expand telehealth access in response to the pandemic. The eligibility windows for these policy changes ranged from March 2020 through the end of the public health emergency (PHE). We focused our analysis on private payer policies that were implemented prior to November 25, 2020. The report provides an overview of the key findings from our analysis and discusses their implications. Among those findings, five stood out:
All of the national insurance carriers voluntarily expanded telehealth coverage for their commercial health plans on a temporary basis during the PHE.
Nearly all major insurers (6 of 7) waived cost-sharing for COVID-19 telehealth treatment services and also for non-COVID primary or urgent care telehealth visits.
Four major insurers agreed to cover limited out-of-network telehealth services, with at least 1 major payer (Anthem Blue Cross Blue Shield) waiving cost share obligations for out-of-network telemedicine visits through Spring 2020.
Six major payers agreed to reimburse providers at the in-person rate, including for audio-only services.
The majority of these expansions expired by the end of 2020, while a limited number of payers aligned expiration with the end of the PHE.
It is important to point out that because we conducted our analysis in Fall 2020, we anticipate that many of the coverage policies discussed here may have not been extended by payers and will have expired by the time this report is published. Still, these changes represent a seismic shift from business as usual in private payer telehealth coverage. While many of the more expansive changes have expired, some payers have extended their temporary coverage into 2021 and a few will become permanent. In particular, the Centers for Medicare & Medicaid Services (CMS) recommendations around audio-only coverage and expanding the originating site to include the home, are likely to become a fixture of major private payer telehealth policies in 2021 and beyond. At least 1 large national carrier has already added several common telehealth services covered during the PHE to their 2021 reimbursement policy. These developments have presented private payers with a unique opportunity to reassess their telehealth coverage policies in light of utilization trends and consumer preferences prompted by COVID-19.
The COVID-19 pandemic triggered a flurry of changes to regulations around telehealth and virtual care – the vast majority of which expire once the public health emergency ends.
The current presidential administration and 116th Congress have each signaled their support for virtual care to various degrees over the past year. But neither took decisive, sweeping action that would permanently enshrine some of the major changes to telehealth policy.
So, the question on the minds of many telehealth advocates as President-elect Joe Biden prepares to take office is: What’s next?
“We are at an inflection point, and inflections bring new challenges,” said former senate majority leader Dr. William Frist, R-Tennessee, during the first day of the American Telemedicine Association’s four-part EDGE policy conference on Tuesday.
“Inflections demand changed perspectives, changed understanding, changed behaviors on our parts,” said Frist, a surgeon who is now a director at Teladoc and partner at Frist Cressey Ventures.
Frist noted that virtual care has exploded in the wake of the COVID-19 crisis. But the next steps, he said, will be safeguarding access to that care.
He noted the importance of allowing telehealth access regardless of patient and provider location, codifying a broader range of practitioners that can provide Medicare-reimbursable telehealth services, authorizing federally qualified health centers and rural health centers to continue offering telehealth, addressing cross-state licensing barriers, and treating all forms of communication equally, with regard to reimbursement, if providers can meet the same standards of care.
“There is a risk that broad telehealth deployment – if not carefully and thoughtfully designed – could replicate the barriers of the traditional bricks-and-mortar health system that produced disparities,” Frist cautioned.
Multiple panelists throughout the day raised payment parity as a particularly thorny issue. Frist noted, for example, while it was necessary to motivate physician participation during the pandemic, “since many overhead costs are totally eliminated in virtual transactions … some of these savings should flow to the patient as well as the provider.”
Similarly, Meghan O’Toole, health policy advisor for Sen. Brian Schatz, D-Hawaii, said “there’s a difference between payment during a pandemic … versus beyond.”
“Congress may not be the best suited to establishing payment rates for certain services,” O’Toole said.
“The [Congressional Budget Office] has consistently evaluated telehealth legislation as very expensive,” added Crozer Connor, senior legislative assistant for Rep. Mike Thompson, D-Calif.
In order for more lawmakers to give their full-throated support to telehealth reform Connor stressed the need for more data to support the quality of virtual patient care, saying, “What we need is payer data.”
“If we offer telehealth as an insurer, does that drive up utilization? Or is there a substitution effect?” Connor continued.
AVIA executive in residence Dr. Molly Joel Coye countered that in her panel, noting that plenty of data regarding telehealth’s effect on care exists, especially from the Veterans Administration.
“We do have data. We just don’t have it at the scale that COVID has now caused telehealth to be used,” Coye said.
Coye and her co-panelist Avalere Health senior advisor Wendy Everett forecast an overall rosy future for telehealth under President-elect Joe Biden’s administration.
“It’s mostly very good news,” Coye said.
She predicted that Biden’s administration will support the idea that broadband infrastructure alone will not be enough for parity in digital health.
It’s not just obtaining access to broadband, she said, but the ability to “pay for data charges, to have the appropriate devices and to have digital literacy” that makes a difference.
She pointed to “what I would call ‘the Geek Squad capability’ to come out and help people when it’s blowing up, and they just don’t know what to do, and they can’t make it work.”
Everett agreed with Coye that Biden’s administration “will absolutely keep the conceptual foundation that the Trump administration put in place.”
However, she noted, “there are some elements that the new administration will need to review.”
Again returning to payment for telehealth, Everett said, “We’ll likely move toward determining some level of fair payment rather than moving toward payment parity across the board.”
She also raised the importance of addressing the multi-channel delivery potential of telemedicine.
“How is [audio-only care] covered? What are we going to do about covering for text, for chatbots, for AI, for other ways of getting healthcare services to people who currently can’t get them?” she said.
One major way the next presidential term will be different, she predicted: “There’s going to be a lot of work done on expanding access to telehealth for those people who are broadly underserved.”
“Think about what they come in facing,” added Coye. “They are under the gun to show the public that they are going to do something really good for them in the next two years.”
Telehealth, she said, “is one of your key ways to make sure the public sees better access resulting from more insurance coverage.”
“We know there’s a very strong focus on equity and on access. But obviously the two are very tied together,” said Everett. If she were given the chance to pitch telehealth to senior government officials, she said she would propose, “Let’s come up with a plan for how to solve that digital divide: how to reduce the inequities and how to move telehealth across the country ubiquitously.”
By: Scott Moody, MHA National Telemedicine Policy Updates:
The Centers for Medicare and Medicaid Services (CMS) released the 2021 Medicare Physician Fee Schedule final rule on December 1, 2020. The 2,165-page final rule adds more than 60 services to the Medicare telehealth list. These services will be covered even after the Covid-19 pandemic has ended. Early on in the Covid-19 crisis, CMS added 144 telehealth services to its coverage list through the end of the public health emergency. Follow the link below for the list of covered telehealth services:
The President signed Bill H.R. 133 into law on December 27, 2020. The law does provide for expansion of Medicare telemental health services; however, it does come with limitations. The law also provides other support for telehealth growth. Please follow the link below for further detail: https://preview.mailerlite.com/n8x5k1
R.7105 – Veterans Health Care and Benefits Improvement Act of 2020
The President signed Bill H.R. 7105 into law on January 5, 2021. The bill requires the VA to ensure that veterans participating in or receiving services under a program for homeless veterans have access to telehealth services. The VA must ensure telehealth capabilities are available to such veterans, VA case managers, and community-based service providers.
R.7187 – HEALTH Act of 2020
On June 11, 2020, US Reps. Glenn Thompson (R-PA) and George Butterfield (D-NC) introduced bill H.R. 7187. The bill proposes to make permanent Medicare coverage for telehealth services provided by Federally Qualified Health Centers (FQHC) and Rural Health Clinics (RHC). The bill also has language eliminating site facility and location requirements for distant site telehealth services. The bill is currently in the House Energy and Commerce Committee and the House Ways and Means Committee.
R.5201 – Telemental Health Expansion Act of 2020
Bill H.R. 5201 proposes to modify the requirements relating to coverage of mental health telehealth services under Medicare. Specifically, the bill removes restrictions that require the originating site (i.e., the location of the beneficiary) to be in a rural area and allows the home of a beneficiary to serve as the originating site for such services. The Bill was discharged from the Committee on Ways and Means on December 24th to go back to the entire House.
R.9035 – Permanency for Audio-Only Telehealth Act
Bill H.R. 9035 was introduced on December 18, 2020 and currently resides with the House Energy and Commerce and the House Ways and Means Committees. The bill proposes to remove geographic restrictions for certain telehealth services and to expand the use of the home as an originating site for certain telehealth services.
R.8755 – Expanded Telehealth Access Act
Bill H.R. 8755 was introduced on November 16, 2020 and currently resides with the House Energy and Commerce and House Ways and Means Committee. The bill proposes to the scope of practitioners eligible for payment for telehealth services under the Medicare program, and for other purposes.
South Carolina Telehealth Policy
H 3230 – Medicaid Mental Health Reimbursement for Telehealth Services
H 3230 was introduced on December 9, 2020. The bill proposes to require the Medicaid program to reimburse practitioners for mental health telehealth services. The bill was referred to the House Committee on Ways and Means.
S 265 – Case of Laws of South Carolina, 1976, By Adding Section 44-7-400
Bill S 265 was introduced by Senator John Matthews on December 9, 2020. The bill proposes to amend the Code of Laws of South Carolina to insert language to prohibit hospitals from utilizing telemedicine to deliver intensive or critical care services and to require such services be provided or supervised by a physician who is board certified in critical care medicine. The bill has been referred to the Senate Committee on Medical Affairs.
Key regulatory flexibilities impacted by the COVID-19 public health emergency include higher Medicare payments for COVID-19 hospitalizations and telehealth reimbursement.
– HHS has renewed the COVID-19 public health emergency, extending key regulatory flexibilities such as Medicare telehealth reimbursement and higher rates for COVID-19 hospitalizations through April.
The 90-day extension of the public health emergency, effective January 21, 2021, will help hospitals and health systems battle the ongoing COVID-19 pandemic in their communities, HHS Secretary Alex Azar said on Twitter on Jan. 7.
“Our work to combat the virus will continue, as will our work to ensure a peaceful and orderly transition,” tweeted Azar, whose tenure as leader of HHS will come to a close when President-elect Joe Biden takes office later this month.
Biden has nominated Xavier Becerra, California’s Attorney General and one of the chief architects behind the Affordable Care Act’s defense in the current Supreme Court case, to be the next HHS Secretary, pending Congressional approval.
This is the fourth time HHS has renewed the COVID-19 public health emergency, with the last being in October.
The public health emergency, first enacted on Jan. 31, 2020, implemented a number of blanket waivers and regulatory flexibilities for healthcare providers to deliver fast, flexible care to infected patients while maintaining access to care for those without the novel coronavirus.
Increased telehealth coverage for Medicare beneficiaries was a key flexibility HHS has offered providers through the public health emergency. The department has added over 200 telehealth codes that are reimbursable during the public health emergency, including emergency department visits, initial inpatient and nursing facility visits, and discharge day management services.
HHS has also allowed more types of providers to bill Medicare for telehealth services given during the public health emergency and granted waivers enabling reimbursement for audio-only telehealth services.
Through the public health emergency, HHS has also paid providers 20 percent more for caring for hospitalized COVID-19 patients and waived major rules, including the long-term care hospital (LTCH) site-neutral payment policy, the LTCH “50% Rule,” and the inpatient rehabilitation facility “3-Hour Rule” for all providers.
The department has also granted providers more flexibility with where they provide care to patients and waived certain reporting requirements for the duration of the emergency.
The waivers and regulatory flexibilities have been critical to provider response efforts to COVID-19, especially since the number of new cases, hospitalizations, and deaths continue to increase across the country.
But healthcare providers are also calling on HHS to make certain flexibilities and waivers part of the permanent regulatory landscape in healthcare. For instance, providers have urged the department to keep telehealth payment parity even after COVID-19 cases go down and can be managed by providers.
“Payment parity is an important policy because it affects their financial stability; in fact, before COVID-19, finances were a significant barrier to their using telehealth at all,” the University of Kansas Medical Center recently said in a Dec. report. “Some practices would not have started using telehealth were it not for COVID-19. The nature of the disease itself (the need for less physical contact and more social distancing) certainly drove some of the increase in telehealth offering and use, but the reimbursement and other policy changes likely also played a part.”
States have started to pass legislation making telehealth payment parity or payment at all permanent, but providers are calling for HHS to set the example and make telehealth a key part of Medicare coverage.
For now, blanket waivers and other regulatory flexibilities will last until April when the HHS Secretary will have to reassess the state of COVID-19 in the country.
For a comprehensive list of waivers and flexibilities, click here.
CARES Act provider relief payments disproportionately went to medically underserved areas, helping providers in already struggling areas to keep their doors open during the peak of lockdowns.
– At the start of the COVID-19 pandemic, the healthcare industry was confused, scrambling, and scared. Patients did not know when and where it was safe to seek care and providers were overwhelmed with patients needing care for a disease they did not know how to treat. Hospitals quickly hit capacity as ICU beds filled with patients needing ventilators while small physician practices had to close because no patients were coming in for care.
The Coronavirus Aid, Relief, and Economic Security (CARES) Act provided economic stimulus and relief throughout the country amidst the COVID-19 pandemic and gave specific funding directly to providers and care delivery organizations. In total, this Provider Relief Fund allocated over $50 billion to Medicare fee-for-service providers for healthcare-related expenses or lost revenue as a result of COVID-19.
As telehealth quickly emerged as a catch-all solution to providers many challenges, Provider Relief Funding could support providers implementing these solutions without seeing a drop in revenue. Supportive policies from CMS and other payers relaxed restrictions previously limiting telehealth’s use and funded telehealth-based care.
Primary care visits delivered via telehealth grew by nearly fifty percent. But providers still needed support to rollout telehealth solutions and other technologies that improved patient access to care and kept safety at the forefront of care delivery. Providers needed to innovate if they were to keep their doors open and adjust practice to meet the demands of the time.
Funding from the CARES Act gave providers a needed economic boost when patient volume was at an all-time low and provide support to rolling out solutions that would keep facilities operating. An additional $18 billion was set aside for Medicaid and CHIP providers, including assisted living facilities. A final $20 billion was allocated for financial losses and changes in operating expenses to providers including, behavioral health providers.
A portion of the Provider Relief Fund was distributed based on the provider’s 2018 Medicare fee-for-service revenue. Additional funding was granted based on provider application, so those providers who were leveraging value-based payments were also eligible for funding.
New York, California, and Texas received the highest total number of payments across all states, according to the Department of Health and Human Services (HHS). Allocation strategy indicated that the areas hit the hardest by the COVID-19 pandemic would receive priority payment.
Over 40,000 payments were given to California providers alone, as this state has the highest number total cases across the county at over 1.5 million, according to data from the Centers for Disease Control and Prevention.
Payments ranged from $1 to $1,196,544,217 but averaged $265,759 for all recipients. HHS appeared to live up to its call as those areas hit the hardest by the COVID-19 pandemic received some of the highest payments.
But medically underserved areas also appear to have received higher total payments and average payments from the Provider Relief Fund than their counterparts in resource-rich areas, revealed an analysis from Xtelligent Healthcare Media.
Medically underserved areas are defined by the Health Resource and Services Administration (HRSA) as geographic areas that lack access to primary care services. Four elements contribute to an area being designated as a medically underserved area:
Rate of primary care providers
Percent of population at the federal poverty level
Percent of population over age 65
Infant mortality rate
A low rate of primary care providers for an area means patients have difficulty accessing care where and when they need it.
As primary care is central to care delivery and often the spoke behind care coordination, limited access to these services and results in poor care delivery and uncoordinated care. Previous research has shown that populations with a high proportion of primary care providers see lower mortality rates and improved life expectancy.
Poverty rates have also long been tied to health outcomes. Social determinants of health such as income and economic opportunity can correspond to a slew of health-related factors from accessibility of care to access to safe housing, all of which impact health outcomes.
Population over the age of 65 is likely also considered an element in the medically underserved designation as older patient populations typically have higher rates of comorbidities and chronic conditions.
These conditions, including diabetes and heart disease, require more and more frequent health services. A higher population over the age of 65 would suggest a stressed healthcare system or at least a healthcare system needing more resources to care for a sicker population.
Similarly, high infant mortality rate suggests poorer health status of mothers and thinned healthcare resources.
So medically underserved areas have the perfect storm of overextended care – fewer providers to care for a greater and more in-need patient population. These areas are in greater need of assistance to meet these needs of their complex patient population.
It is, therefore, reassuring that analysis from Xtelligent Healthcare Media found 240,461 more Provider Relief Fund payments made to providers in medically underserved communities.
Data on provider payments from HHS was paired with the HRSA’s indication of medically underserved populations to understand the relationship between relief payments and county-level resources.
The average payment for providers in medically underserved areas was over $20,000 higher than those in resource-rich environments. Not only does this data indicate that those areas in the greatest need received more payments, but they also received higher valued payments.
The difference in total payments to medically underserved areas compared to non-medically underserved areas was over $66 billion.
While reassuring that providers the most in need of additional resources were receiving aid, this data does not reflect the total impact of Provider Relief Funding in these communities because the data is only based on the payments accepted by providers at the time of analysis. Pending payments were not a part of analysis and reports from July show that nearly $100 billion had yet to be dispensed. Hopefully, this pending aid will continue supporting providers who are already stretched thin because of resource limitations in their communities and the impact of COVID-19 on their practice.
While priority was given to areas hit the hardest by COVID-19, the current wave of infections is sweeping the country irrespective of state and county lines. How HHS dispenses the remaining funds will be critical to support providers in areas with the most need.
It is a positive indication that medically underserved counties received over $66 billion more in aid than non-medically underserved populations, but is this enough?
For providers in areas where broadband is limited, HHS funding may not be enough to support equal access to telehealth services for their entire patient population. Or cancer care clinics whose patients are at the highest risk for developing severe COVID-19 may not have enough funding to provide safe and effective home care. Continued support to these areas will be critical moving forward as the pandemic continues to sweep the country.
Palmetto Care Connections (PCC) is the telehealth network for South Carolina that offers telehealth support services to rural and underserved health care providers.