Relaxed payer regulations and the future of telehealth
Daily life has changed drastically since the COVID-19 outbreak. For healthcare practices, it has disrupted care delivery and operations, leading many to wonder if they will make it to the other side of this public health crisis.
Amid this instability, telehealth has proven crucial to maintaining cash flow and care continuity. In April, Forrester Research predicted virtual care visits would exceed 1 billion in 2020, including 900 million related to COVID-19. Originally, the firm projected only 36 million visits for 2020.
As practices work through each phase of the pandemic — response, recovery, and redesign — telehealth will continue to play a key role in helping providers manage patient health, support high-risk patients, and better monitor care. When integrated with the EHR and other digital health technologies, virtual care holds even greater potential.
Since the official declaration of a public health emergency by Alex Azar, Secretary of Health and Human Services (HHS), CMS has taken swift action to address requests from the healthcare community. While these telehealth expansions apply only for the duration of the public health emergency, provider and patient advocacy groups want them to continue on a permanent basis.
Members of Congress on both sides of the aisle have begun drafting legislation to end uncertainty around expanded telehealth services. This legislation would pave the way for HHS to relax requirements even without an emergency declaration. On behalf of our clients, Greenway supports such efforts by HHS and further encourages all payers to support these initiatives.
Read on for an overview of these changes and reasons why we support continued telehealth flexibility.
“Some of our clinics dropped to about 50% before they implemented telehealth. Now, many of our schedules are back to about 100%. Most are back to about 90% of patient volume, which is totally attributed to telehealth. It’s just been a godsend.”Jenny Williamson, Intergy Clinical Coordinator, HealthLinc Community Health Center
Relaxation of CMS telehealth regulations
In March, following President Trump’s declaration of a national emergency, CMS relaxed its telehealth requirements for the duration of the public health emergency. The Coronavirus Aid, Relief, and Economic Security (CARES) Act further expanded Medicare telemedicine services to include 80 additional services that practices can provide via telehealth. These initial sweeping changes from CMS included allowing phone-based telehealth and enabling providers to bill telehealth visits at the same rate as in-person visits.
On April 30, at the direction of the Trump administration, CMS issued a second round of sweeping changes dependent on the public health emergency. This announcement of additional flexibility to telehealth provisions followed a letter from 37 senators to Secretary Azar and CMS Administrator Seema Verma.
This bipartisan call for equal telephone-based health services reimbursements and the bipartisan Creating Opportunities Now for Necessary and Effective Care Technologies (CONNECT) for Health Act demonstrates the motivation in Congress to meet constituent demands for expanded access to care.
“Telehealth always had a bright future, but the relaxed regulations made it a viable option for practices to provide care in the current environment,” said David Cohen, Greenway’s Senior Vice President, Product Management. “These changes open the door to virtual care that could integrate seamlessly with the EHR. We hope they will remain in place.”
Here are a few additional changes CMS announced April 30:
- CMS added physical therapists (PTs), occupational therapists (OTs), and speech-language pathologists (SLPs) as practitioners who can provide telehealth visits.
- Hospitals can bill for remote services by hospital-based practitioners to Medicare patients registered as hospital outpatients, including services conducted when the patient is at home. Additionally, hospitals may bill as the originating site.
- CMS has broadened the services that may be provided via audio-only.
- FQHCs and RHCs can now be paid to provide telehealth services as “distant sites.” This designation enables these organizations to bill for telehealth services.
The future of telemedicine
Greenway supports the changes CMS has rolled out to make telehealth more feasible for practices and applauds legislation such as the CONNECT for Health Act, which has recently gathered support and co-sponsors across party lines. However, if CMS brings back its pre-pandemic regulations and no longer reimburses telehealth visits at the rate they are currently reimbursed, many practices will be unable to afford these services.
“We were willing to do telehealth with little or no pay to ensure that our patients would get the care they needed and that our surgery centers could have surgeries and procedures scheduled on the other side of this,” said Linda Watson, Chief Operations Officer, Long Beach Gastroenterology Associates. “When I heard about the changes from CMS, that was when I took my first deep breath that ‘Okay, we’re going to survive this.’”
Due to COVID-19-related restrictions on elective visits and procedures, Long Beach Gastroenterology Associates saw about 80% of its business quickly evaporate — until the CMS changes in March made telemedicine a financially viable option. She credits telemedicine for helping her practice maintain about 70% of its previous schedule.
“I think we’ll always have an element of telehealth. Of course, it depends on what happens with reimbursements,” Linda said. “Certain elderly patients or those who are immunocompromised are going to have to stay at home. I think we’re going to have a long-term element of telehealth that will have to be reimbursed.”
In a March survey by Sage Growth Partners (SGP) and Black Book Market, 36% of respondents said they would find a new provider if theirs did not offer telehealth. With consumer demand increasing the pressure to provide telemedicine, practices are finding they must implement these services to stay in business — and are relying on the temporary changes from CMS and other payers for reimbursement.
“Telehealth always had a bright future, but the relaxed regulations made it a viable option for practices to provide care in the current environment."David Cohen, Greenway’s Senior Vice President, Product Management
A lifeline for critical care and business continuity
During the COVID-19 crisis, practices have seen patient volume decline by an average of 60% and have seen revenue decrease by an average of 55%, an MGMA survey found.
Ethan Bing, Practice Administrator, Medical Colleagues of Texas, said telemedicine allowed his practice not only to stay in business, but to keep its staff employed and maintain paychecks.
“If it weren’t for telemedicine, we would be in a very difficult spot between trying to pay our bills and keep our staff on the payroll, at least for long-term outlook,” he said.
Christine Kelly, President and Owner of CMK Consulting, said her clients will continue to offer telehealth as long as it’s paid for.
“I don’t have a practice that’s not doing telehealth,” she said. “It’s been absolutely crucial to cash flow. The first two weeks, before they implemented telehealth, they were seeing so few patients.”
There’s no doubt that telehealth has played a key role in allowing practices to deliver care — and keep their doors open — during this unprecedented public health crisis. But whether CMS will permanently extend the changes to telehealth regulations remains to be seen.
“You have to make that telehealth visit payable at a high enough rate that a provider can keep their doors open,” Mike Popp, President, MJP Consulting, said. “If a practice had half of their visits as telehealth, the previous payment structure would not allow a medical practice to survive that scenario.”
For some of Mike’s clients, implementing telehealth was a lifeline to deliver care to patients in critical need. A 14-provider practice is using telemedicine to maintain 100% of its pandemic visits, providing care to dialysis patients. Two rural health clinics in northern Wisconsin are maintaining about 90% of their previous patient loads to ensure care for patients with diabetes, hypertension, and other conditions.
“Out of tragedy, we try to find the ‘positives.’ I think this is going to be one of the ‘positives’ of this pandemic — the widespread use of telehealth and better treatment for homebound patients,” Mike said. “I’m hopeful that CMS stops and takes a look at this and creates a better funding stream.”
We are hopeful that CMS will continue the expansion of telemedicine regulations and that all payers will continue to reimburse for these services, even after the public health emergency has ended. These services have proven critical to delivering care and ensuring business continuity.
Looking further ahead, we are eager to see how integrating virtual care with an EHR system and other digital health technologies — such as patient engagement and remote patient monitoring, for example — can complement in-office care, allowing providers to expand offerings to patients, and ultimately, to help patients achieve better health.
“Considering today’s healthcare environment and the infrastructure breakdowns caused by the pandemic, telehealth will be key to providing care going forward,” said Dr. Geeta Nayyar, Chief Medical Officer of Greenway. “It offers solutions to staffing shortages and other issues in the healthcare industry.”
As COVID-19 disrupted their operations, many Greenway clients forged ahead with telehealth. We are inspired by their willingness to adapt quickly to ensure their patients have access to quality care. “We heard our clients and have engaged with our U.S. Representatives and Senators to support continued efforts like the CARES Act, and potential future laws like the CONNECT Act, that will have significant impacts in the redesign of the healthcare delivery system”, said Susan Kohler, RN and Chief Compliance Officer of Greenway.
As practices begin to recover, we expect significant changes to how providers deliver care. The use of telehealth and telemonitoring will shift thinking on how and when patients can receive care and how providers can best monitor their health. Especially for high-risk patients with complex or chronic conditions, care delivery will need to evolve to ensure their safety, while effectively managing their health. Virtual care may be here to stay, and Greenway is committed to supporting our clients and the healthcare industry in reshaping patient care.
If your practice hasn’t yet implemented telehealth, or if you’re just getting started, view our recent webinars for tips for success: Best practices for telehealth — before, during, and after a visit and COVID-19 telehealth billing: the latest expert advice.