Telemedicine – a word that has become very familiar to all in recent memory. From a fairly unused concept a few years ago to the recent norm, COVID-19 has assisted in making Telemedicine a staple in our healthcare system.
We have seen frequent articles and research on Telemed services and expansion. Recently, Health and Human Services (HHS) data cites billed visits increasing to 52.7 million in 2020; a 63-fold increase from previous assessments mostly due to the expansion of the virus and increased need for remote care.
There are varied discussions on the presence of Telemedicine in the future. Insurance carriers, State Medical Boards, Specialty Associations, and additional organizations are maintaining varied stances and views on the direction and future of these services to patients and clients.
With the volume of information and data available on Telemedicine and reimbursement, what should a Health Center or medical practice expect or plan for in 2022 and beyond?
It is a complex question without a specific answer at the present time. What are the views and positions of patient care entities, insurance plans, and Government entities? How could these positions affect my entities care to patients?
As an example, we are familiar with an entity that increased remote visits and maintained payer policies during the core of the virus outbreak. They recently received a five-figure refund request stating that employer groups had changed their policies on remote visits, thus the refund request.
Let’s look at proposed changes that could affect the operations, policies, and revenues of our centers and practices.
Government and Legislative Initiatives
Reimbursements
Medicare has maintained payment allowances for most COVID testing, visits, and immunizations, while permanent allowances for this care is pending.
We expect HRSA will maintain their request for additional reporting on visits and conditions from Health Centers regarding the virus.
Inter-State Telemedicine Visits
Healthcare professional groups are lobbying Congress to extend present Telemedicine variances and waivers through the year 2024.
The Telehealth Extension and Evaluation Act was recently introduced in the US Senate
(telehealth.org/what-you-need-to-know-about-the-telehealth-extension-and-evaluation-act) for consideration. The legislation would establish a two-year extension for certain COVID-19 geographic restrictions and allow Medicare beneficiaries to access telehealth even when at home. The initial proposal also allows controlled substances to be prescribed via a telehealth encounter, as well as some durable medical equipment (DME) and laboratory testing.
Many states have retracted unlimited inter-state virtual visits and care as of this writing (www.fsmb.org/siteassets/advocacy/pdf/states-waiving-licensure-requirements-for-telehealth-in-response-to-covid-19.pdf). Any future virus outbreak will assist in determining if states move back to unlimited inter-state care.
Legislative Initiatives
The No Surprises Act protects people covered under group and individual health plans from (www.cms.gov/nosurprises/Ending-Surprise-Medical-Bills) receiving unexpected medical bills when they receive services from out-of-network providers at in-network facilities. We expect this new legislation, with the final wording in process, may affect referral patterns on Health Centers and provider practices.
Medicare
Medicare is allowing payment for behavior health visits furnished by Rural Health Clinics and Federally Qualified Health Centers via telehealth or telephone calls.
The Centers for Medicare & Medicaid Services (CMS) is additionally eliminating geographic barriers allowing patients unlimited access to Telehealth services (www.cms.gov/Center/Provider-Type/Federally-Qualified-Health-Centers-FQHC-Center).
Private Insurance Carrier Policies
Reimbursements
Most private (commercial) carriers have maintained increased provider payments schedules during the pandemic. Many added temporary benefits such as lowered or no deductibles and/or copayments and out of pocket expenses.
The direction of these carriers regarding policy and reimbursement has started to be seen as the virus diminishes; waived out-of-pocket expenses and additional benefits are starting to transition back to original policies. As we have seen prior to the pandemic, entities are starting to receive refund requests and takeback notices because of these policy changes.
Hospitals and Associations
Hospitals and Associations such as the American Hospital Association (AHA) have adopted
a positive stance in accepting Telemedicine services as the norm moving forward (www.aha.org/factsheet/telehealth).
While the rate of reimbursement has been of concern for some of these entities, the increased rate of patient virtual services has influenced hospitals to accept the established or contracted reimbursement rates with little pushback.
Federally Qualified Healthcare Centers
Health Centers have found Telemedicine to be of great assistance in maintaining patient care needs as well as care continuity and maintaining staff wellness during the virus outbreak. Telehealth has additionally assisted these facilities in extending specialist and subspecialist encounters to Health Center populations.
In addition to traditional services, increased Telehealth encounters have assisted in delivering additional service offerings remotely such as chronic care management, monitoring of intensive care unit (ICU) patients, and Telepharmacy services.
The Consolidated Appropriations Act of 2021 (www.cms.gov/CCIIO/Programs-and-Initiatives/Other-Insurance-Protections/CAA) assists Health Centers in providing Telehealth
services to remote populations in addition to additional services and enforcements.
Conclusion
COVID-19 has changed our everyday habits and work environments in permanent ways, with many predicting additional transitions to come.
Health Centers and provider offices have been proactive in adapting to rapid legislative and HHS implementations to meet changing clinical demands.
Even with the recent CDC relaxation of COVID precautions, predictions on what to expect this year are mixed. Future steps with the virus outbreak will affect planning and policy implementations.
Well respected authors have made non-specific projections for 2022, with most illustrating many items are yet to be measured; thus, projections cannot be accurately made.
As contributors to services in Health Centers and provider offices, our 2022 virus priorities appear to be:
Staying vigilant to national, state, and regional virus trends and volumes
Safeguarding our office teams and clinical staffs through immunizations, use of Personal Protective Equipment, (PPE) and education
Continue to implement patient friendly and clinical efficient methods of care such as Telemedicine
Monitor national and state legislative actions that affect care and reimbursement rates
Stay interactive with your state and national Associations on pending and proposed rule changes
Consider increased communications with your state and federal representatives on your entities needs and potential legislative actions
We are hearing that final chapters in managing the virus may be near; let’s be positive in that these final verses are being written at present.
We solute the efforts of your Health Centers and practices to date; your patients and families appreciate your efforts.
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