The Covid-19/Corona virus is quickly spreading its gangly tentacles across the globe. This pandemic has brought out the best in people as new partnerships form to combat a common enemy. While the pandemic tears across the globe, so to do the unprecedented and innovative changes in pharma, manufacturing, and care delivery. As such, a relaxing of rules and quick adoption of telehealth continues to expand.
Amidst the press for a biologic solution to Covid-19, the federal government has taken strides to expand the breadth of, and loosen restrictions on, “telehealth.” As noted in my Forbes.com article (Telehealth Continues to Change the Face of Healthcare Delivery – For the Better, September 2019), telehealth is gaining acceptance as a care delivery “modality.” During these pressing healthcare challenges now, more than ever, remote “visits” and patient monitoring are essential to ensure “social distancing,” provide greater access to care, and reduce unnecessary medical visits.
As discussed previously, telehealth, broadly defined, is the exchange of medical information via remote communications, whether via phone, computer, or image sharing. The Centers for Medicare and Medicaid Services (CMS) issued a waiver (1135 waiver) in early March indicating a willingness to relax rules/regulations regarding virtual visits in an attempt to facilitate the delivery of care while encouraging patients to avoid the hospitals and medical practices, where possible. While these adjustments pertain to Medicare in the last few days some commercial insurance companies (e.g., United Healthcare, etc.) have begun to follow suit. The salient question is can hospitals and private practices adjust/adopt quickly to ramp up telehealth services? While the 1135 waiver is intended to provide a temporary reprieve from regulations, one hopes that this broader telehealth footprint is embraced to further expand the delivery of care to underserved markets and improve patient access.
The Genesis
As federal and state governments and businesses flex to meet current healthcare demands and balance distancing requirements, the Trump administration issued an 1135 waiver which empowers the Secretary of HHS to waive certain rules/regs in governmental programs to broaden availability of telehealth care delivery and modalities. As of March 6, Medicare can pay office, hospital, and select other visits for telehealthcare across the country. Clinicians who can provide these services include doctors, nurse practitioners, physician assistants, psychologists, and licensed clinical social workers. Also during this unprecedented time the Office of Inspector General (OIG) is curbing co-pay and deductible collection (“cost-sharing”) for telehealth programs.
Prior to the Covid-19 outbreak and the 1135 waiver, Medicare only paid for telehealth on a limited basis. However, as of March 30, more than 80 additional services became payable for telehealth under this temporary umbrella. These include, but are not limited to, ER visits, initial and discharge nursing facility visits, and home visits (provided the service[s]) is/are provided by a clinician allowed to offer telehealth services).
What do these new “relaxed” rules mean to the average Medicare patient? The 1135 waiver paves the way for certain expanded “virtual services” such as:
· telehealth
· virtual check-ins, and
· e-visits.
Telehealth:
Medicare beneficiaries can use telecommunications for office, hospital, and other services that are usually, otherwise, performed face-to-face. The clinician must use audio/visual (AV) telecommunications that allows for “real time” communication between the patient and the clinician. These are subject, though, to state laws. Applicable care professionals include doctors, nurse practitioners, physician assistants, nurse midwives, certified nurse anesthetists, clinical psychologist, clinical social workers, registered dieticians, and other nutrition professionals.
The delivery of telehealth services requires a robust AV connection where the clinician and the patient can exchange real time information.
The 1135 waiver suggests that the patient have an “established relationship” with the clinician but during the Covid emergency “…HHS will not conduct audits to ensure that such a prior relationship existed for claim submitted during this public health emergency.” During the pandemic Medicare will reimburse telehealth services furnished in any healthcare facility and in the patient’s home.
As of March 30, CMS is allowing telehealth to fulfill many face-to-face visit requirements for clinicians to attend to their patients in in-patient and rehabilitation facilities along with home health and hospice patients. Patients can use available apps with AV capabilities.
CPT codes (and, thus, billing codes) for these services are available.
Virtual Check-Ins:
In early March, established patients (e.g., those with a clinician/patient relationship) could obtain “brief” services via phone, video, or “image.” However, as of March 30, CMS suggested these visits could occur for new patients, as well. These services are not limited to rural or underserved areas.
Medicare will pay for virtual check-ins to reduce unnecessary trips to the doctor’s office. The patient must verbally consent to receive a “virtual” check-in service. These “visits” can occur via phone, AV, secure text, email, or a patient portal on a computer system.
Virtual check-ins have the flexibility of occurring with a simple phone call vs. the AV requirements of the telehealth visit.
These visits are reimbursable via a series of G codes.
E-Visits:
E-visits can occur in “all types” in all locations and settings (e.g. patient’s home; rural vs urban, etc.) for established Medicare patients and may include non-face-to-face communications without going to the doctor’s office (using a patient portal, for instance).
Patients should have an established relationship with the clinician (e.g., you’ve been to this clinician before). The patient must start the inquiry but the clinician can educate the patient on e-visit options thereby offering the patient the opportunity to “initiate” an e-visit. Patients must verbally consent to an e-visit. As of March 6, co-insurance and deductibles apply (no further guidance as of March30).
These visits are reimbursable via CPT and G codes.
While these robust changes generally apply to governmentally administered healthcare programs, one hopes that insurance companies will continue to latch on to this model with expanded zeal as the Covid-19 pandemic reverberates across the country. As of today, the telehealth, and broader healthcare community, is fluid, dynamic and constantly evolving. Clinicians can expand their care and reach Medicare patients via telehealth given the flexibility of current federal regulations; now clinics must scramble to deploy tele-solutions under stressful and challenging times.
As a side note, I’m thankful to live in this country. While we struggle as one, we reach for our common humanity and, generally, the best rises to the top. Thank you to all the healthcare providers; too, thanks to all the hardworking folks in the supply chain keeping the supermarkets stocked and the delivery of essential goods and services humming along.
Comparisons:
Summary
For more information visit the CMS website/newsroom/fact-sheets
