The declaration of COVID19 as a pandemic and the United States declaring a national emergency to help contain and enhance treatment access have resulted in a number of changes to ease potential regulatory burdens or barriers in healthcare. Like so much happening as a result of the pandemic, the changes have the potential to fundamentally change the healthcare industry not just during the time of the emergency declaration.
Of particular note are coordinated announcements from various agencies within the federal Department of Health and Human Services connected to the provision of telehealth services. The advancement and relaxation of regulations are designed to increase access to telehealth services and make it easier to deliver the services.
The scope of telehealth services now available, as explained by the Centers for Medicare and Medicaid Services (CMS), can be broken into three main categories: (i) telehealth visits, (ii) virtual check-ins, and (iii) e-visits.
Telehealth Visits – For purposes of Medicare, a telehealth visit is between a patient and a clinician that uses interactive audio and video. The visits generally cover visits that could otherwise occur in person. As such, the telehealth visit is being structured as a replacement for an office visit for the time being. The telecommunication platform must provide real-time communication between the patient and the clinician. CMS will also turn a blind eye to the established patient requirement, which essentially means a telehealth visit can occur with both new and established patients. Additionally, a patient will be permitted to receive telehealth services while in their home, which reinforces the goal of maintaining social distancing.
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Virtual Check-Ins – A virtual check-in is meant to be a brief discussion between a clinician and a patient, which can be audio-only. Further, CMS expects that in most instances the patient will be the one to initiate a check-in. The check-in cannot be related to an office visit from the previous 7 days or lead to a full visit within 24 hours after the check-in. Additionally, the patient must verbally agree to the check-in. Lastly, check-in is only billable for an established patient, which follows from the description of the service as being focused on a quick interaction between a patient and their clinician.
E-Visit – An e-visit is similar to a virtual check-in, but must be patient-initiated and is expected to occur through the patient portal. Further, the service can cover up to a 7 day period between the communication initiated by the patient and interactions with the clinician. Before being able to bill for the e-visit, the patient must be established with the clinician and made aware of the fact that reimbursement will be sought for the services.
On top of opening up the scope and ability to provide telehealth based visits, a bigger change is to reimburse the telehealth visits at the same level as in-person visits. Arguably, one of the primary barriers to telehealth adoption up until this point has been a lack of or lower reimbursement. The incentivization of patient interactions through telehealth means not only with healthcare organizations potentially be able to somewhat mitigate the financial fallout from telling patients to remain home, but gives a good alternative that could stabilize access. Stabilizing access is important since reducing non-emergent issues cannot be put off indefinitely.
Source: HIT Consultant
