The adaption to telehealth services has changed the way the healthcare industry has used technology to optimize the convenience of servicing their patients in a safe and efficient way with the advantages of delivering health care cost savings, convenience, and the ability to provide care to people with mobility limitations, or those in rural areas who do not have access to a local doctor or clinic. According to the Department of Health and Human Services, the federal restrictions have relaxed while developments for risk adjustment audit and compliance plans continue to evolve in order to stay ahead of changes. The public health emergency has modified risk adjustment and payers greatly.
Medicare Advantage and Medicare Plans
According to a Centers for Medicare & Medicaid Services (CMS) regarding “Applicability of Diagnoses from Telehealth Services for Risk Adjustment,” the agency expanded their telehealth services for Medicare Advantage (MA), Medicare Cost Plans, Programs of All-Inclusive Care for the Elderly (PACE), and demonstration organizations. However, diagnoses resulting from telehealth services must be “provided using an interactive audio and video telecommunications system that permits real-time interactive communication” to meet the risk adjustment face-to-face requirement. MA plans do not accept telephone-only visits as a valid risk adjustment documentation source because they do not provide the face-to-face requirement. Centers for Medicare and Medicaid Risk Adjustment Programs requires that a telehealth service must be descriptive of a face-to-face service furnished by a qualified healthcare professional and is an acceptable source of new diagnoses telehealth visits that are considered equivalent to face-to-face interactions, but they are still subject to the same requirements regarding provider type and diagnostic value. Several Bills are now on the books.
Protecting Rural Telehealth Act
Passed to ensure that underserved community health providers can continue accessing virtual care beyond the end of the public health emergency.
- Waive the geographic restriction to allow Medicare patients to be treated from their homes.
- Allow rural health clinics and Federally Qualified Health Centers to serve as distance sites for providing telehealth services.
- Lift the restrictions on "store and forward" technologies for telehealth. Currently this is only allowed in Hawaii and Alaska.
- Critical Access Hospitals can directly bill for telehealth services.
- Allow payment parity for audio-only health services for clinically appropriate appointments.
- Ensure Granite Staters to access the care they need without traveling long distances so that healthcare providers can easily connect with patients while earning additional income needed to keep their doors open.
CONNECT for Health Act
Passed to allow expansion of telehealth service and make COVID-19 telehealth flexibilities, improve health outcomes, and make it easier for patients to safely connect with their doctors.
- Allows the Centers for Medicare & Medicaid Services (CMS) to waive certain restrictions, such as geographic restrictions, for services provided in high-need health professional shortage areas.
- Excludes mental health and emergency medical services, as well as services provided at rural health clinics, federally qualified health centers, and Indian Health Service facilities, from such geographic restrictions.
- Allows the CMS to generally waive coverage restrictions during national emergencies.
Additionally, the Medicare Payment Advisory Commission must report on information relating to the access of Medicare beneficiaries to telehealth services at home. The Center for Medicare and Medicaid Innovation may also test alternative payment models relating to expanded telehealth services.
Telehealth Modernization Act
Specifically, the bill extends certain flexibilities that were initially authorized during the public health emergency relating to COVID-19 (i.e., coronavirus disease 2019). Among other things, the bill allows (1) rural health clinics and federally qualified health centers to serve as the distant site (i.e., the location of the health care practitioner); (2) the home of a beneficiary to serve as the originating site (i.e., the location of the beneficiary) for all services (rather than for only certain services); and (3) all types of practitioners to furnish telehealth services, as determined by the Centers for Medicare & Medicaid Services. Congress is very interested in expanding Medicare's telehealth coverage beyond the COVID-19 emergency, as the growing number of bills would attest.
- The COVID-19 Telehealth Program Extension Act which aims to give COVID-19 the Telehealth Program another $200 million to allow the Federal Communications Commission to fund more telehealth programs.
- The COVID-19 Emergency Telehealth Impact Reporting Act of 2020, Keep the Telehealth Options ACT both of which call on the HHS to collect data on telehealth use during the pandemic for an in-depth study on its effectiveness.
- The Telehealth Expansion Act of 2020, The Advancing Telehealth Beyond COVID-19 Act and The Protecting Access to Post-COVID-19 Telehealth Act, all of which aim to make permanent certain telehealth freedoms enacted during the pandemic.
- The Equal Access to Care Act, which would allow care providers to use telehealth in any state to treat patients in any location for up to 180 days after the end of the COVID-19 emergency.
- The Helping to Ensure Access to Local Telehealth Act of 2020, which focuses on extending telehealth coverage to FQHCs and RHCs; and
- The Telehealth Response for E-prescribing Addiction Therapy Service (TREAT) ACT, which focuses on expanding telehealth coverage for substance abuse treatment.
PETTIGREW has the compliance and optimum support to service telehealth advantages for our clients.