Back in March, the Centers for Medicare and Medicaid (CMS) expanded telehealth for Medicare beneficiaries, as COVID-19 was drastically increasing the need for virtual appointments. This included expanding Medicare telehealth so all beneficiaries could receive telehealth in any location, including their homes. They also announced additional temporary rules and waivers to expand Medicare telehealth services, making it easier for healthcare providers to offer a wider range of telehealth services to patients.
Now that these changes have become common practice over the past few months, it’s hard to say if the previous rules for telehealth will come back into play immediately once the established patient health emergency (PHE) has passed. The initial PHE that was set back in January expired on July 25, however it was recently expanded by 90 days by the U.S. Department of Health and Human Services (HHS). Along with this extension, the CMS is currently reviewing how these changes have impacted Medicare beneficiaries to recommend whether these changes should be permanent parts of the Medicare program.
So while it’s possible the current changes (or at least some of them) become standard practices, it’s also possible that the changes will be terminated once the PHE is officially over. For many dermatologists and other doctors, it was necessary to quickly implement new and expanded telehealth programs made possible by the changes, in order to keep up with patient care. But if/when the changes are removed, you may need to re-adjust your telehealth practices to fit the previous standards.
What are some areas should you be thinking about?
The CMS changes expanded the number of reimbursable Medicare telehealth services. But once the PHE expires, you need to be aware of what services will still be reimbursable and which ones won’t. Perhaps none will change or maybe more will be added to this list, but either way, it’s important to stay informed.
Typically, Medicare telehealth services need to have real-time communication between doctor and patient using audio and video components. But the CMS changes allowed payment for some audio-only visits. If you’re using audio-only visits, be aware that these may be removed if the stricter requirements return. Another flexible change announced early on dealt with what types of telehealth applications and platforms could be used. Communication technology sources like Skype and Zoom were previously considered unsafe for discussing protected health information (PHI), under HIPAA requirements. However, the changes made these acceptable to use during the PHE. If you’re using platforms like this for telehealth, you should be prepared to switch to other sources if they’re deemed unacceptable under HIPAA again.
Generally, any Medicare-enrolled patient is eligible to receive medically-necessary telehealth services, though an established relationship with the doctor may be required beforehand. But, CMS hasn’t been enforcing this requirement during the PHE. Following the PHE, make sure you know what relationship requirements are kept, removed or put back into effect. Also, prior to the PHE, Medicare patients were required to be in certain eligible areas and geographic locations, which were often healthcare facilities. The patient’s home was often not considered eligible. But this was waved during the PHE, so Medicare currently pays for telehealth services to patients no matter where they’re located. That location flexibility could go away though unless made permanent.
Cost to Patients
Generally, Medicare coinsurance and deductibles are applied to telehealth services. But during the PHE, the HHS Office of Inspector General (OIG) (link to OIG blog) has allowed providers to reduce or forego cost-sharing for telehealth services paid by federal healthcare programs. After the PHE, doctors will once again need to collect cost-sharing amounts. If this relates to you, it’s a good idea to communicate this to affected patients, so they’re aware of this when the PHE ends.
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