The waiving of Medicare telehealth rules today may be a way of easing the COVID-19 burden on doctor’s offices, clinics, and hospitals. And it may, in fact, help with federal and state social distancing efforts by sparing Medicare beneficiaries a trip to the doctor for a health matter completely unrelated to COVID-19.
Certainly, the telehealth industry has been champing at the bit since the American response to pandemic took off last week.
“This is telehealth’s moment to shine,” Rafid Fadul, MD, chief medical officer for Wheel, an Austin, Texas, telehealth company said in an interview last week with Managed Healthcare Executive.
But loosening the telehealth rules could test the capacity of the telehealth companies. And while telehealth has been useful for screening patients with garden-variety upper respiratory infections, often resulting in some reassurance and no treatment, screening people for COVID-19 will be uncharted territory. And, of course, screening for COVID-19 is not the same as testing for it, which has to be done in person.
Michael Barnett, an assistant professor at the Harvard T.H. Chan School of Public Health whose research into health care delivery has included some studies of telehealth, said that it will be the “edge cases” when some symptoms suggest the possibility of COVID-19 but not definitely that will be difficult to handle via telehealth. “It is going to be the gray area that is going to be the challenge,” he said during a phone interview last week.
Fadul have developed an algorithm for screening COVID-19 cases uses information from the CDC.
Barnett also discussed supply side of telehealth services and how the direct-to-consumer telehealth companies could have capacity problem if COVID-19 results in a surge of telehealth usage.
Help-wanted signs are going up. In a tweet yesterday, Amwell said it was looking for doctors in all 50 states and nurse practitioners in Arizona, Washington D.C., Iowa, Oregon, Rhode Island, Utah, Virginia, and Washington. Wheel posted a video of Fadul on Saturday urging physicians, nurse practitioners, and physicians to learn more at wheel.com and “come see how you can be at the forefront of the effort to contain the COVID-19 virus and help the nation as a whole.”
Teladoc put out a press release on Friday that said its visits had increased 50% and were occurring at clip of 15,000 per day. Other companies are jumping into the fray. Zocdoc announced yesterday that it is offering free chats with nurses through Nurses 1-1 to people with COVID-19 questions.
Telehealth companies who hire clinicians are offering one form of telehealth. But another version of telehealth is as an added service provided by clinicians. Barnett said he foresees problems with clinicians incorporating telehealth into their practices in a hurry as part of the COVID-19 response: “Organizational change doesn’t happen that quickly even a pandemic like this,” he noted.
CMS posted a factsheet and a 19-question FAQ on its website today about the loosening of the Medicare telehealth rules. The FAQ is especially helpful and worth your time if you are trying to figure out the waiver.
Here are some of the important takeaways:
- The waiver is retrospective of March 6, when the corona preparedness legislation was signed into law and will last until the public health emergency declared by HHS secretary is over.
- The waiver is not [emphasis added] limited to visits by people who are worried that they are infected with SAR-CoV-2 or have a COVID-19 diagnosis. The FAQ makes the point that the telehealth waiver is part of the federal government’s social distancing policy, and that Medicare beneficiaries could, for example, use a telehealth visit to get a prescription refill that is unrelated to COVID-19.
- The waiver allows the patient to receive telehealth services in all settings, including their homes. Prior to waiver, beneficiaries had to be in an “eligible originating site.”
- The rule that the beneficiaries must have a prior relationship with provider will not be enforced.
- The acceptable technology rules for telehealth have allowed devices with audio and video capabilities, i.e., smartphones. But the FAQ says the waiver “explicitly allows the [HHS] Secretary to authorize the use of telephones that have audio and video capabilities during the COVID-19 PHE [Public Health Emergency].”
- CMS says it is waiving penalties for HIPAA violations against who use FaceTime or Skype to conduct a telehealth visit.
- The FAQ says that out-of-pocket costs for patients with “original” aka traditional Medicare won’t change, but that HHS is providing “flexibility” to providers to reduce or waive cost sharing.
- Providers can bill for telehealth services as if the service was furnished in-person but the claim needs the 02 code used to indicate that it was provided remotely via telehealth.
- For billing code and other purposes, CMS puts “virtual check-ins” of 5-10 minutes and “e-visits” conducted through online portals into their own category, into separate categories from telehealth visits, even though “telehealth” is commonly used to describe these kinds of services. The suspension of the established relationship rules for telehealth visits does not apply to the virtual check-ins and e-visits.