Cheat sheet: 3 imperatives to leverage telehealth against Covid-19

These latest changes open Medicare reimbursement to more types of providers, interactions, and facilities, and they allow CMS to make new services eligible faster. As with previous changes, they are not limited to Covid-19-related services.

Primer: Telehealth reimbursement 101

4 important changes to Medicare telehealth

1. More types of providers can deliver telehealth services.
   
   

   All health care professionals that are eligible to bill Medicare for their professional services can now use telehealth during the remainder of the outbreak. These professionals include physical therapists, occupational therapists, and speech language pathologists.

   Previously, only physicians, nurse practitioners, physician assistants, certified nurse midwives, nurse anesthetists, licensed clinical social workers, clinical psychologists, and registered dietitians or nutrition professionals could provide telehealth services.

2. More audio-only visits are eligible for reimbursement.
   
   

   CMS has added behavioral and patient education services to the list of services eligible as audio-only visits. Additionally, some evaluation and management services provided via audio-only telephone will be reimbursed at the same rate as in-person visits. This is an important change for these services, as the bottom end of the range for in-person rates ($46) is higher than the top end of the range for telephone rates ($41). These changes are retroactive to March 1, 2020.

   The full list of additional services that meet the audio-only requirements can be found here.

3. Rural health clinics and federally qualified health clinics will be paid for telehealth services.
   
   

   Medicare beneficiaries located in rural and underserved areas can access care from home in accordance with the CARES Act. These clinics had previously been considered "distant sites" and could not be paid to provide telehealth services.

4. New telehealth services can be approved faster.
   
   

   Additionally, CMS announced that new telehealth services will be added on a sub-regulatory basis. Instead of following the typical rulemaking process, CMS will consider requests by practitioners to speed up the process of adding new telehealth services. This change is intended to expand the array of eligible telehealth services as providers get familiar and creative with the use of telehealth.

Verma's message: "There's absolutely no going back"

Like previously announced changes, this newest expansion is effective only for the duration of the public health emergency. However, many providers and systems are beginning to plan for a permanent expansion of telehealth services—even in the absence of an indication from payers, including Medicare, about the future of reimbursement beyond this initial phase of the Covid-19 epidemic.

Recent comments from CMS administrator Seema Verma suggest that Medicare telehealth may look much different from its pre-Covid-19 applications. The Wall Street Journal's editorial reported that Verma called telehealth a "clear example of untapped innovation." According to the Journal, Verma also said, "I think the genie's out of the bottle on this one. I think it's fair to say that the advent of telehealth has been just completely accelerated, that it’s taken this crisis to push us to a new frontier, but there's absolutely no going back."

While CMS has not yet given a clear indication on how it will address telehealth after the public health emergency is lifted, Verma's comments indicate an openness to preserving the recent widespread adoption of telehealth. Specific restrictions on secure communication and cost-sharing could eventually be restored, but providers who make smart investments now in their capacity to provide telehealth services are likely to see big payoffs down the road.

How Covid-19 is transforming telehealth—now and in the future

Covid-19 has transformed telehealth from a “nice-to-have” program into an essential element of care delivery. Parallel demands to limit patient travel, prevent potential exposure, and preserve clinical capacity all have telehealth as a solution.

The sudden attention from providers, payers, and consumers will also have enormous consequences for telehealth adoption in the future.

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