CMS announced it is expanding Medicare reimbursement for a wider range of telehealth services. The expanded scope of reimbursed services is intended to limit patient travel and preserve provider capacity in response to COVID-19, and will continue throughout the federal coronavirus public health emergency.
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Available services are not limited to COVID-19-related visits. Patients can receive regular office visits (including evaluation and monitoring), mental health counseling, and preventative screenings as telehealth services.
The changes represent a significant departure from Medicare's previously restrictive rules on telehealth reimbursement. Limitations on where, how, and with whom patients can access telehealth visits have been relaxed, as have restrictions on providers' flexibility to waive or reduce patients' cost-sharing obligations.
4 important changes for Medicare telehealth reimbursement
- Patients can access telehealth visits from home.
Eligible originating sites for telehealth visits now include patients' homes and "any healthcare facility." Previous limitations to specific types of facilities or rural areas are lifted.
- Patients and providers can connect through their smartphones.
Smartphones—or "telephones with audio and video capabilities"—are authorized for telehealth visits. HHS will waive HIPAA-related penalties for providers who deliver telehealth services in good faith using everyday video chat technologies such as FaceTime or Skype. Providers' flexibility to use non-secure communication like this is typically constrained to a 72-hour window, but HHS wants to expand that option during the COVID-19 public health emergency.
HHS recommends that providers should inform patients of potential privacy risks of using these forms of communication and enable all of those systems’ encryption and privacy modes when in use.
- Patients don’t need an existing relationship with a provider to get a reimbursed telehealth visit.
CMS wants both new and existing patients to be eligible for reimbursed telehealth visits. So while the Coronavirus Preparedness and Response Supplemental Appropriations Act defined qualified providers for telehealth as those whom Medicare had reimbursed for services that were furnished to a specific patient within the past three years, HHS will not conduct audits to enforce those requirements. That opens the door to new patients to receive telehealth visits during the public health emergency period.
Virtual check-ins (brief check-ins via a telecommunications device to determine if an in-person visit is required) and e-visits (patient-provider communication via an online portal) continue to be available only to established patients.
- Providers can waive or reduce cost-sharing requirements.
Typically, providers must collect co-insurance or deductible amounts from patients or face penalties under federal anti-kickback regulations. In an effort to make sure patients can access appropriate care, providers will not be penalized for eliminating or reducing patients’ cost-sharing obligations.
2 things that haven't changed about Medicare telehealth reimbursement
CMS' changes to Medicare telehealth reimbursement have not been completely transformative. Restrictions remain in place on the nature of patient-provider interactions and what services and providers are eligible.
- A Medicare telehealth visit must be a real-time, audio-visual interaction.
A telehealth visit must use interactive audio and video communication between a patient and a provider. Telephone, messaging, and other online interactions do not qualify for the expanded reimbursement opportunity, though they still qualify for shorter-duration virtual check-ins and e-visits.
- Qualified providers and eligible services are unchanged.
The types of providers who can deliver telehealth services are unaffected by recent changes to reimbursement policy. Physicians, nurse practitioners, physician assistants, certified nurse midwives, nurse anesthetists, licensed clinical social workers, clinical psychologists, and registered dietitians or nutrition professionals may provide telehealth services within the scope of their practice.
The kinds of eligible services for Medicare telehealth reimbursement also remain consistent with previous policy. The only change is that these services can be provided to patients in any location.
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