"Telehealth" has been one of the hottest topics in healthcare throughout 2021 as its prevalence surged as a result of the ongoing COVID-19 pandemic. To accompany the 63-fold increase from 840,000 visits in 2019 to 52.7 million telehealth visits in 2020, CMS Policy , providers, and payers have been forced to rapidly adapt to this new standard of care. This article summarizes how telehealth has impacted the public, CMS policy changes and future proposals, and aspects of telehealth billing.
Before we break down the history and future of telehealth, it's important to understand what telehealth even is.
To use the CDC's definition, telehealth is "the use of electronic information and telecommunication technologies to support and promote long-distance clinical health care, patient and professional health-related education, public health and health administration" [CDC].
Telehealth is a broader term than its frequently interchanged counterpart "telemedicine" which more specifically refers to when a provider performs services for a patient through electronic communication. The full, legal, definition of services is available in 42 CFR ยง 410.78 - Telehealth services. For the sake of simplicity, this article will use the broader term "telehealth" throughout.
Pros and Cons of Telehealth
The surge of telehealth necessity spurred a lot of analysis on the service in an attempt to understand its efficacy and potential unintended consequences.
For example, the "Digital Divide" of racial and ethnic differences in access to technology as a concept has been around for a while, where studies have found that white populations are far more likely to have access to home computers and internet use than minority populations such as Black and Latino [Fairlie, 2003].
A recent study published in the Journal of the American Medical Informatics Association [Weber and colleagues, 2020] studied telehealth use in 76,845 patient encounters during the COVID-19 pandemic to determine if there were racial or ethnic differences in its use. The team found that demographic factors such as race/ethnicity and age were significantly predictive of telehealth use, where white populations were more likely to use telehealth than Black or Hispanic populations, and patients over 65 years of age were significantly less likely to use telehealth services.
While telemedicine may provide convenient care options for some, technology accessibility is a pre-requisite for fully realizing its capabilities. Programs such as Washington State establishing Wi-Fi hotspots for its area [Washington Hotspots] or the Veteran's Health Administration supplying tablets for veterans [VA tablets] are examples of ways to increase telehealth accessibility.
Another concern from a provider perspective is outlined by Ashwood's research in 2017 "Direct-To-Consumer Telehealth May Increase Access To Care But Does Not Decrease Spending". Ashwood's paper found that while per-episode spending was lower if the patient had a telehealth visit compared to in-person, overall healthcare spending increased due to patients receiving telehealth visits who otherwise would not have sought care. However, research from Katebi and Kane from Americans For Prosperity found less healthcare utilization for telehealth patients, contradicting Ashwood's 2017 research, demonstrating the need for further analysis of the service.
Despite meaningful barriers, the value is apparent where telehealth is accessible. The COVID-19 Healthcare Coalition's patient analysis shows positive sentiment from patients in their ability to reduce travel costs, time off work, reduce potential COVID exposure, as well as overall high satisfaction with quality of care.
Telehealth Policy and Regulations
The necessity for telehealth throughout the pandemic also spurred significant legislative changes, both on a state and federal level. One of the first major changes was the expansion of the 1135 Waiver. Once a President officially declares a state of emergency and the HHS Secretary declares a public emergency, the 1135 Waiver allows flexibility to waive or modify certain healthcare regulations. In the case of COVID-19, this use of the waiver allowed Medicare to cover more telehealth services than it normally would, as well as greater flexibility for the cost-sharing of telehealth visits that went into effect March 6, 2020. The CMS Newsroom report and letter from the Association of American Medical Colleges provide additional detail on the specifics of these expansions. Moving forward, other telehealth-focused legislation like the Telehealth Modernization Act were introduced but didn't receive significant traction. Most recently in November 2021, CMS finalized their 2022 Medicare Physician Fee Schedule that includes extensions of the emergency measures that were granted to telehealth services to be enacted even after the public emergency has ended.
Telehealth Billing
Along with all of the policy changes being made, it's imperative for providers to stay in the know on how these are influencing the way they bill. For example, the new POS Code 10 for "Telehealth Provided in Patient's Home" goes into effect on January 1, 2022, and previously, with the invocation of the Public Health Emergency, changes were made to the applicability of items such as the CR and DR Condition Codes, Modifier 95 (indicating telehealth service) and other key billing items [CMS MLN]
In the rapidly evolving industry, missing updates like these means increases in denials and lower reimbursement is inevitable, resulting in detrimental losses of revenue for providers.
If your organization has experienced an increase in telehealth visits, itโs essential to ensure that any existing issues leading to denials are addressed immediately and effectively to prevent further lost revenue. To learn more about how we can reduce your claim denials through root cause determination with machine learning, read more about our process and how CARMA, our "Claims and ReMittance Analysis" system, works to help get you paid what you deserve on your claims.
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