June 11, 2020 – Telehealth use has increased dramatically in a matter of weeks, enabling providers to continue seeing patients despite social distancing and shelter-at-home restrictions due to COVID-19. But these advancements could be lost after the pandemic without telehealth reimbursement parity, provider groups are telling policymakers.
“[C]hanges in payment policy address some of the biggest issues facing physicians as they struggle to make up for lost revenue and provide appropriate care to patients,” the American College of Physicians wrote in a June 4th letter to CMS Administrator Seema Verma.
The College recommended that CMS maintain payment parity between audio-only evaluation and management (E/M) claims and their in-person equivalents, as well as between all telehealth and in-person visits after the public health emergency has ended.
“This extension should last at least through the end of 2021, or until such a time when effective vaccines and treatments are widely available, with an option to extend it even further, or consider making permanent, based on the experience and learnings of patients and physicians who are utilizing these visits,” the letter stated.
For the duration of the official public health emergency, CMS has granted payment parity for a wide range of telehealth services that industry leaders have said are essential to the healthcare industry’s response to COVID-19. The regulatory flexibilities significantly expanded Medicare coverage of services traditionally only paid for if a provider renders them during an in-person visit. New policies also widened the list of providers and locations eligible to bill for telehealth services.
Many private payers have followed suit, enacting their own telehealth coverage and reimbursement policies during the crisis. This led to a 4,347 percent increase in telehealth claim lines among the privately insured population from March 2019 to March 2020.
But the telehealth flexibilities are only temporary, expiring at the end of the public health emergency period – a restriction that providers are saying could result in the closures of organizations already struggling to make ends meet.
“Given the uncertainly around the timeline for a COVID-19 vaccine or treatment, many expect that the virus will continue to spread well into 2021,” the College stated. “Therefore, as the need to contain the virus and maintain appropriate social distancing protocols continues into next year, it is unlikely that in-person visits to practices will return to pre-pandemic levels as patients remain uncomfortable with making these in-person visits and physicians schedule fewer patients to be seen in the office.”
Payment parity, as well as clear telehealth billing guidance from CMS, is necessary for ensuring a smooth and safe transition to normal operations for the healthcare industry, the College stated. But others are also urging policymakers to consider permanent implementation of other telehealth billing flexibilities, such as the ability to provide care remotely in the homes of patients.
“While these outpatient services are not technically considered telehealth services, they are furnished in the same manner as telehealth services. Several of the services are also similar to services that can be furnished by physicians through telehealth,” healthcare improvement company Premier Inc. recently told HHS.
Payment for remote patient care during the public health emergency has allowed in some cases for “unexpected improvements in care” during the pandemic, the College stated. Clinicians, for example, have been better able to identify social determinants of health impacting clinical outcomes.
“It is imperative that physicians and payers have an opportunity to evaluate the impact of these changes and adapt before moving forward,” the College advised.
Premier also encouraged CMS to explore regulatory and statutory changes that would allow other provider types, such as institutional providers, to furnish and bill for telehealth services even after the public health emergency period expires. This would be a key move to modernizing the Medicare telehealth benefit, the company stated.
“During the height of the COVID-19 pandemic, waivers cleared away cumbersome barriers and allowed health systems to save lives in the process,” said Blair Childs, Premier’s senior vice president of public affairs.
“Many of these measures were policies for which we’ve been advocating for many years. In all practicality, these waivers were pressure tested during the pandemic, and proved to be effective at modernizing and improving healthcare delivery. Smart, effective ideas should be made permanent policy. There’s no reason to revert back to the status quo just because patients may seek different avenues for treatment.”
Other recommendations from Premier included allowing providers outside of rural areas to provide telehealth services, expanding telehealth services to occupational therapy and behavioral health services, and allowing for audio-only visits when applicable. The permanent implementation of these recommendations was also supported by 93 percent of respondents to a recent Premier survey.
The College also encouraged CMS to continue geographic restriction and telehealth cost-sharing waivers, as well as flexibilities for direct supervision, remote patient monitoring services, interstate licensure flexibility, and facility fee payment for provider-based departments.