By attending this webinar, you will learn about the rationale for telemedicine, and the historical restrictions on payment for it.
Overview:
Under the Social Security Act, reimbursement for telehealth under Medicare has been subject to stringent restrictions.
Only patients in certain identified practice settings in rural,
physician-underserved areas were eligible. Care into the patient's home
was not covered.
Only certain providers were eligible. With rare
exceptions (demonstration sites in Hawaii and Alaska), only real-time,
audio-video communications were eligible. And, only a rather modest
number of CPT codes were eligible. These provisions are still good law.
In 2015, however, the first modification of these rules appeared,
allowing reimbursement, still subject to extensive restrictions, for
chronic care management. Because a co-pay had to be charged, patient
consent was required, for services that the patient had previously
received at no charge.
Plenty of other limitations were imposed as
well. For example, the patient has to have access to care management
services 24/7, a comprehensive care plan has to be developed, only 1
practitioner/month is eligible for reimbursement, and providers have to
document that clinical staff spent 20 minutes of non-in-person time in a
given month.
For the first time, however, distance care services
provided by staffers, as opposed to qualified HCPs, and delivered by
email or phone, for example, as opposed to by videoconferencing, could
satisfy Medicare's requirements for reimbursement. In 2018, CMS
developed the highly creative concept of communication technology-based
services ("CBTS"), distinguished from telemedicine on the theory that
these are not simply substitutes for in-person care, but are inherently
electronic in nature and thus outside the scope of the telemedicine
reimbursement rules of the Social Security Act.
Consent and co-pay
provisions attend these services also, as well as somewhat onerous
"related visit rules" that to some degree limit the value of this new
opportunity. Nevertheless, it is now possible to be reimbursed for
remote evaluation of patient images and videos; for so-called "virtual
check-ins," designed to determine whether an in-person evaluation is
necessary; and for interprofessional consultations. In addition,
reimbursement for remote patient monitoring ("RPM") is both more
generous and easier to obtain under CBTS reasoning than it had been
before this innovation. In particular, originating site and geographic
restrictions on RPM reimbursement are now things of the past. By no
means are these the only changes of note.
The Bipartisan Budget
Act of 2018 and the SUPPORT Act have also expanded reimbursement
opportunities as well. Under the BBA, Medicare Advantage plans may offer
"additional telehealth benefits" as part of "basic benefits" not
otherwise available in Original Medicare under Part C, and may "treat
them as basic benefits for purposes of bid submission and payment by
CMS." Renal dialysis facilities and a beneficiary's home may now serve
as originating sites for dialysis and monthly ESRD-related clinical
assessments.
Coverage is now available for acute stroke telehealth
services in any hospital, CAH, mobile stroke unit, or any other site
determined appropriate by the Secretary, in addition to the current
telehealth originating sites. Under the SUPPORT Act, CMS adjusted the
telehealth reimbursement rules for treating individuals anywhere in US
with substance use disorder or a co-occurring mental health disorder.
The
Agriculture Improvement Act of 2018 provides funding for both
telehealth grants and for broadband expansion. In short, the
reimbursement landscape has changed substantially, and these
developments augur well for potential growth in telemedicine and all the
benefits it will bring to both patients and providers.
Why you should Attend:
Patients and employers are demanding distance care because it is
convenient; it expands access to care, including specialty services
often hard to obtain in many areas; it can save costs; and it improves
patient satisfaction. Some 75% of all US hospitals now offer some form
of telehealth service. Growing numbers of physicians are doing so as
well, especially in such specialties as radiology, psychiatry,
cardiology, and emergency medicine.
Knowing how to offer such
care, and how to get paid for it, is no longer merely desirable; it has
become essential. Unfortunately, however, reimbursement has long been a
problem with this sort of care, especially for Medicare beneficiaries.
Those attending this webinar will learn about the rationale for
telemedicine, and the historical restrictions on payment for it.
We
will then consider the rise of chronic care management and the erosion
of the historical barriers to payment a) for care at home and b) for the
services of clinical staff; CMS's new regulatory approaches to
reimbursement; and the several communication technology-based services
that for the first time allow reimbursement for store-and-forward
telemedicine, brief check-ins with patients, interprofessional consults,
and expanded access to remote patient monitoring.
We will also
examine Congress's recent legislative decisions to expand coverage for
ESRD, stroke care, substance use disorder management, and HHS's ET3
pilot program, which provides equal financial incentives for ambulances
to deliver patients to an ED, to urgent care, or to offer care in place
via telemedicine.
These changes do not solve all telemedicine
reimbursement problems, but they are significant changes, nonetheless.
If you ignore these changes, you may be denying access to services for
some patients, and you are leaving money on the table at the same time.
Areas Covered in the Session:
- The Rationale for Telehealth
- The Traditional Payment Restrictions
- The legal limits on CMS's ability to reimburse distance care Services
- Chronic Care Management and the change it Represents
- The Evolution in CMS's thinking about Distance Care
- The Rise of communication Technology-based Services
- Congress's growing Enthusiasm for Telehealth
- New Opportunities for Distance care for ESRD, Stroke, and SUD
Who Will Benefit:
- Hospital Revenue Cycle Managers
- Hospital CEOs
- CFOs
- Hospital Counsel
- Billers and Coders
- Telemedicine Service Providers
- Telemedicine Platform Companies' executives and sales and Revenues Professionals
- Office Managers for Medical Practices
- Lawyers Advising Health care Organizations and Professionals
- Managed Care Providers