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During the COVID-19 public health emergency different modes of telehealth have become rapidly adopted and utilized to provide adequate care to the millions of patients across the country. For many, the first thought when the word telehealth is mentioned is a live video interaction between the provider and the patient. However, telehealth understands many different technologies and tools that can help deliver care

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ATA Comments on CMS 2022 PFS Proposed Rule

On September 1st, 2021, American Telemedicine Association (ATA) has submitted and shared their response to the Centers for Medicare and Medicaid 2022 Physician Fee Schedule proposed rule. In the submission, they provided valuable comments to some of the key items including the in-person requirement for certain telemental health services, allowing additional providers to provide telehealth services to eligible patients, appropriate technologies that can be used to access and provide telehealth services, an extension of Category 3 services, and remote physiological and therapeutic monitoring.

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CMS telehealth proposed coverage expansion

During the pandemic, many patients and providers got a chance to experience the benefits of telehealth. While this opportunity was enabled by the loosened regulations due to the state of emergency, the future and application of telehealth and remote patient monitoring is now in the hands of the healthcare lawmakers that determine reimbursement policies.

In the 2022 Physician Fee Schedule, the Centers for Medicare and Medicaid Services proposed an extension of most of the COVID-19 relaxations until the end of 2023. Such extension would allow for sufficient time to assess which services should be permanently kept after the public health emergency. In addition, the proposal extends coverage for telehealth sessions treating substance abuse and mental health issues.

The other proposed changes include the elimination of geographical restrictions, allowing the patient’s home to be the originating site for the mental health video telehealth coverage, with a requirement that there is at least one in-person visit every six months. When it comes to audio-only telehealth, CMS proposed changes to their previous requirements. If passed, these changes would allow for audio-only telehealth to be used for mental health diagnosis, evaluation, and treatment.

“CMS is proposing to limit the use of an audio-only interactive telecommunications system to mental health services furnished by practitioners who have the capability to furnish two-way, audio/video communications, but where the beneficiary is not capable of using, or does not consent to, the use of two-way, audio/video technology,” the agency said. “CMS is also proposing to require the use of a new modifier for services furnished using audio-only communications, which would serve to certify that the practitioner had the capability to provide two-way, audio/video technology, but instead, used audio-only technology due to beneficiary choice or limitations.”1

CMS also proposed expansion of Medicare coverage for real-time mental health telehealth treatment provided by FQHCs (Federally qualified health centers) and RHCs (Rural health clinics). As of right now, neither FQHCs nor RHCs have been listed as distant site telehealth providers. Such expansion of Medicare coverage can make a tremendous difference for underserved populations.

Expansion of RPM (Remote patient monitoring) coverage is still being discussed.

“Notably, the current proposal does not include any changes to the use of RPM CPT codes. This comes as a disappointment to many who had hoped CMS would remedy the limitations imposed by the 16 days’ transmission requirement,” states Carrie Nixon in a blog.4

However, the 2022 Physician Fee Schedule includes a new category of CPT codes called “remote therapeutic monitoring”.  The new RTM codes with previously introduced RPM codes give healthcare providers more options for reimbursement. This proposal has greatly expanded what was understood by RTM, however, there are still plenty of unknowns and details that need to be clarified. It is expected that these unknowns will be clarified in the upcoming months so that the providers can confidently plan to implement or enhance existing telehealth and remote patient monitoring offerings.

Any feedback on the 2022 Physician Fee Schedule propositions must be submitted by September 13th, 2021.

Sources:

1. https://mhealthintelligence.com/news/cms-expands-telehealth-coverage-in-proposed-2022-physician-fee-schedule?eid=CXTEL000000638360&elqCampaignId=20198&utm_source=nl&utm_medium=email&utm_campaign=newsletter&elqTrackId=22d95a823e30476eb9285afd2181c205&elq=56965d0907f54d13b90e6f12132cb6a8&elqaid=21080&elqat=1&elqCampaignId=20198

2. https://mhealthintelligence.com/news/cms-expands-remote-patient-monitoring-coverage-in-proposed-2022-pfs?eid=CXTEL000000638360&elqCampaignId=20251&utm_source=nl&utm_medium=email&utm_campaign=newsletter&elqTrackId=6070d455d7ea47f58c700d912dab4057&elq=e3ab24d69eb1434da87ad6c4aee4dcb6&elqaid=21086&elqat=1&elqCampaignId=20251

3. https://www.physicianspractice.com/view/remote-therapeutic-monitoring-s-debut-what-you-should-know-for-now-

4. https://nixongwiltlaw.com/nlg-blog/2021/7/14/new-remote-therapeutic-monitoring-cpt-codes-introduced-in-proposed-2022-medicare-physician-fee-schedule

Patient feedback on telehealth usage during COVID-19

In order to understand the impact of this sudden shift in telehealth usage due to COVID-19, the research team led by professionals from Mayo Clinic, ATA, DiMe, and other prestigious medical institutions have conducted an impact study focusing on three main areas of interest – telehealth insurance claims, direct physician feedback, and direct patient feedback.

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What COVID taught us about remote patient care

Our whole lives we are taught that in order to get adequate care we need to make that trip to a hospital or a clinic and have a long wait in the waiting room – all for approximately 15 minutes of the provider’s time. After such a visit, it is not uncommon that we ask ourselves – could I have saved myself a trip and took care of this at home?

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Medical Debt and COVID-19

Ever since the onset of COVID-19, hospitals have been fully packed with patients experiencing more severe symptoms. Depending on the symptoms and the recommended course of treatment, hospitalized patients tend to stay in the hospital between 4 and 21 days on average.

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Telehealth may lead to more in-person visits

During the global pandemic, telehealth has experienced a rapid expansion. It is undeniable that the COVID-19 pandemic has influenced the shift in healthcare from mostly in-person care to predominantly virtual care particularly during the peak of infections. However, there is a lot of discussion on the role of telehealth in the post-pandemic world and how it will fit into the existing healthcare system.

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Demand for telehealth after COVID-19 pandemic will continue to grow

Before the global pandemic, telehealth was considered a novelty in patient care. However, due to the COVID-19 restrictions, the role of telemedicine shifted from an additional tool that was only used occasionally, to an essential tool that is used to treat many patients every day. Providers, some of whom have never used telemedicine before, had to quickly adapt and start providing virtual care to their patients. Many providers went from no telemedicine at all to almost completely operating virtually. This rapid change of treatment delivery in just a matter of months has made a significant impact on the different aspects of telehealth.

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