Healthcare providers have unprecedented freedom to care for patients utilizing telehealth and other healthcare technology-enabled capabilities, based on recent waivers related to the COVID-19 Coronavirus public health emergency.
In the nThrive webinar, “Revenue Enhancement Through Patient Care Improvement During and After the Public Health Emergency,” Virginia Gleason, JD, MPA, BSN, likened recent legislation relaxing telehealth restrictions to “letting a genie out of a bottle,” discussing the limits of the law as well as ramifications for patients and providers during the COVID-19 response and beyond.
“The genie is not likely to be put back into the bottle,” said Gleason, responding to audience feedback that greater use of telehealth “is long overdue.”
Prior to Public Health Emergency Waivers issued by the Centers for Medicare and Medicaid Services (CMS) in March, telehealth was restricted to patients residing in rural areas, who were required to be physically present at a healthcare facility with real-time audio/video capabilities when patient services were provided. Additionally, telehealth services were limited to an approved CMS list.
On March 6, following the declaration of a Public Health Emergency (PHE) on January 31 in response to the COVID-19 Coronavirus, President Trump signed the Telehealth Services During Certain Emergency Periods Act of 2020 (TSDCEPA), which is part of the larger Coronavirus Preparedness and Response Supplemental Appropriations action. CMS subsequently issued expanded Telehealth Waivers on March 17.
With the passage of the Coronavirus Aid, Relieve and Economic Security Act (CARES act) on March 27, the Secretary of Health and Human Services now has broad authority to waive any of the Social Security Act statutory Medicare coverage requirements related to telehealth. It is unknown at this time to what extent the Secretary will exercise this authority.
To date, the Secretary has issued waivers related to geographic restrictions, added to the list of telehealth services and allowed the use of a broader range of healthcare technology to name a few. During the public health emergency, geographic restrictions are waived, allowing:
- Medicare telehealth visits using telecommunication systems between provider and patient anywhere in the country and without traveling to a designated medical facility
- Virtual patient check-in’s (5-10 minutes) with providers via telephone or other approved telecommunications devices are now available for new as well as existing patients (with consent)
- E-visit communications with providers via an online patient portal are also available to new and existing patients (with patient consent)
It is important to note that Virtual check-in’s and E-visits are virtual healthcare technology services that are not classified under telehealth and were available prior to the waivers with certain restrictions. Other virtual patient solutions that can be leveraged to improve care include remote patient monitoring and ambulatory care management.
The Interim Final Rule implementing the CARES Act was published on March 20, with a mandatory 60-day comment period. As such, the final telehealth regulations will likely be published after the worst of the pandemic is past.
Based on these existing waivers, “beneficiaries get a broader range of services,” Gleason explained, adding that the changes ensure patients “get the care they need while staying in their home to help flatten the curve related to the spread of the novel Coronavirus.”
Covered telehealth visits
While Gleason stressed that much ambiguity still exists, the new telehealth rules currently include physicians, emergency and hospice visits, as well as nursing facility initial admit and discharge and some therapy services (PT/OT/ST). Practitioners who can provide telehealth include:
- Advanced Practice Providers
- Clinical psychologists
- Clinical social workers
- Registered dietitians
- Nutrition professionals
As social distancing is in place and healthcare organizations ramp up nationwide for COVID-19 Coronavirus peaks, Gleason shared that telehealth is expected to become a very important part of not just providing acute management and maintaining patient care and health solutions for infected patients quarantined at home, but safely managing those with chronic health conditions. Utilizing telehealth and other healthcare technologies, such as remote patient monitoring, can also help to replace lost revenue resulting from elective procedure cancellations, which represent a high percentage of hospital revenue.
“Hospitals are reporting that revenue is down by as much as 50 percent right now,” she said, emphasizing that telehealth, remote monitoring and other innovative healthcare technology capabilities can help sustain quality care while helping to offset the financial loss. “These technologies have been shown to improve outcomes,” Gleason added, making them a win-win.
“With telehealth and remote monitoring, patients not requiring hospitalization can be sent home with a pulse oximeter and other equipment to monitor their condition. These same capabilities can be utilized to monitor chronic patients as they shelter in place. The key clinical data is reported to dashboards monitored by medical personnel. The staff monitoring the dashboards do not have to be in the same location as the physician who ordered the monitoring. All of this is available now and allows physicians to focus on the most acutely ill patients while continuing to monitor patients who are not requiring hospitalization.”
Revenue potential long-term
While it is anybody’s guess whether the waivers expanding the availability to telehealth will remain in place following the Public Health Emergency, if they do, Medicare beneficiaries will have better access to healthcare, ultimately meeting Medicare’s goal to improve the health of its beneficiaries. Even if the waivers for telemedicine end after the emergency, remote patient monitoring was in place before the waivers and, as such, will remain in place to provide impactful patient solutions. Medicare’s stated goal for reimbursement of remote patient monitoring and chronic care management is improving the health of Medicare patients with chronic medical conditions.
As Medicare moves toward a Merit-Based Payment system for physicians, reimbursement focuses on maintaining health. The expansion of telehealth during this emergency has shined a light on the benefits of remote healthcare technologies and the long-term positive economic impact could be significant. Taking into consideration the average size of a primary care practice and the number of patients with chronic medical conditions, Medicare reimbursement for remote monitoring ranges from approximately $150,000 to $267,000 per physician with reimbursement potential exceeding $1 million if monitoring 500 patients annually.
“This is reimbursement available for keeping patients healthy outside of the clinic and hospital setting. Providers get timely clinical information that allows for better decisions based upon continuous and comprehensive data. It is the value of remotely monitoring patients and getting reimbursed appropriately for what you are doing to care for your patients,” Gleason said.