TELEHEALTH


doctors to get paid for certain virtual visits with patients to determine if they need an in-person office visit. The code is worded this way because federal law forbids Medi- care from paying for telemedicine services that replace in-person office visits, except in certain rural areas.


“You don’t want to overregulate something, but you want to feel comfortable about what it is and why it’s a great opportunity for people in Florida to get the care they need at home. We need to take those federal regulations [from CMS] and make them applicable in each state.” --Lauren Faison


For providers to qualify for the reim- bursement, the service they provide must be to an established patient who has seen the treating provider within the past three years, and it may not be related to a service provided within the past seven days nor lead to a service or procedure within the next 24 hours or soonest available appoint- ment. Essentially, Medicare wants the virtual check-ins to be quick, for one-off medical questions and condition assess- ments, rather than for a follow-up or triage that leads to an office visit, according to the Alliance for Connected Care, an orga- nization devoted to promoting telehealth as a standard of care.


For the most part, telehealth advocates


are applauding the new CMS regulation. “We think it will significantly increase the number of people we serve and make [care] more convenient, while allowing for more flexibility into those types of encounters. And you may see an uptick in different kinds of health conditions [tele- health could be used for] just because we can address and assess more people. For us, it’s a win,” says Salgado. Back in Georgia, lawmakers recently pushed ahead with a pair of telemedicine bills that would enable providers outside of Georgia to deliver virtual care in the state, while mandating that payers cover telehealth services at the same rate as in-person services. Salgado says that the public health department is heavily pri- oritizing addressing the issue of statewide


Lauren Faison


served areas of the country—nearly half of U.S. states have yet to join the agreement. Some state boards have also sought to pre- vent or limit the expansion of telehealth, citing patient safety concerns. As explained by Jay Backstrom, digital imaging and telehealth practice leader at the Illinois-based consulting firm Impact Advisors, in some states there are even requirements that a physician who is pro- viding the virtual service has to have an office in that state.


Arkansas, for one, has a ways to go to


improve its telemedicine policy. It’s one of the last states to comfortably allow


broadband availability as well, by making sure there is broadband access for every- one in the state, regardless of where one may be. “That has not been the case in the past,” she asserts. Indeed, state-to-state differences in laws


and reimbursement policies have only made things more confusing. Something as simple as how states define telehealth versus telemedicine, for instance, could vary. In Florida, there isn’t even a clear definition about what telehealth is, says Lauren Faison, service line administrator for population health and telemedicine at Tallahassee Memorial Healthcare System. “You don’t want to overregulate some- thing, but you want to feel comfortable about what it is and why it’s a great oppor- tunity for people in Florida to get the care they need at home. We need to take those federal regulations [from CMS] and make them applicable in each state,” she says. For some providers, obtaining licenses


across state lines has long been a challenge, as they have historically had to apply for and pay for licenses in those states—a costly and time-consuming process. In 2017, the Interstate Medical Licensure Compact officially began accepting appli- cations from qualified physicians who wished to obtain multiple licenses from participating states. While the Compact is expected to expand access to healthcare— especially to those in rural and under-


a telehealth visit with a new patient to take place before an in-person one does. Recently, the state shot down a bill that would have permitted healthcare providers to meet with new patients via an audio-only phone; those against the legislation argued that at the least, an audio-visual virtual care


Jay Backstrom


platform be leveraged. So any provider doing telehealth with Arkansas patients has to have an Arkansas medical license, as Arkansas has not yet joined the Interstate Medical Licensure Compact. “You can’t have a hub of telehealth service providers outside of that state,” says Backstrom.


Will reimbursement move the needle enough?


Although stakeholders seem pleased with some of the latest changes Medicare has made to reimburse providers for telehealth services, some questions still remain about how much this specific policy will drive change. For the virtual check-ins that CMS will now be paying for, providers will be reimbursed at a rate of $14 per visit in the first year. But this is compared with $92 per visit for the corresponding established patient visits, said CMS in its nearly 2,400- page physician fee schedule final rule. The agency noted in its rule, “Because of the low payment rate relative to that for an office visit, we are assuming that usage of these services will be relatively low.” What’s more, CMS also wrote in its final


rule that it expects the financial impact of paying for the communication technology- based services will be an increase in Medi- care costs since it predicts “the number of new or newly billable visits and subsequent treatments will outweigh the number of times that communication technology- based services will be used instead of more costly services.”


The agency stated, “We estimate that usage of these services will result in fewer than 1 million visits in the first year but will eventually result in more than 19 million visits per year, ultimately increas- ing payments under the PFS [physician


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