What lies ahead for reimbursement of telehealth services

In light of several positive developments this year, the landscape for further use of and reimbursement for telehealth services looks bright.


Telehealth is revolutionizing the way physicians think about and deliver healthcare, extending the doctor’s office directly into patients’ homes, and connecting primary care providers, specialists, counselors and other types of providers to better leverage resources and knowledge.

According to a 2017 Aruba Networks report, 64 percent of healthcare organizations are currently using technology specifically for patient monitoring.

This extended healthcare reach is revolutionary for patients, particularly those who are unable to access in-person treatment because of physical or geographical limitations. It also has potential cost savings by enabling physicians to keep an eye on patients outside of their office, which will let them identify symptoms earlier and help prevent expensive treatments down the line.

Payers are catching on to these benefits as well. If there’s one takeaway from the digital health trends seen during the first half of 2018, it is telehealth’s growing importance and impact—particularly in regard to Medicare reimbursement.

Even though telehealth has the potential to create significant efficiencies and save money, and quality-based reimbursement models are on the rise, fee-for-service model reimbursement still plays a significant role in the success or failure of telehealth programs.

That’s why the decisions made in the first half of this year regarding telehealth Medicare reimbursements were so crucial. This began with the two-year budget deal signed in February, which included parts of the Creating High-Quality Results and Outcomes Necessary to Improve Chronic (CHRONIC) Care Act.

Sen. Brian Schatz (D-Hawaii) praised the new provisions as “the most significant changes ever made to Medicare,” adding that the legislation “will improve health outcomes for Medicare patients, especially those who live in rural areas or [who] have to make a big effort to get to the doctor’s office, and will make sure that Medicare is ready for the future, when telehealth plays an even bigger role in healthcare.”

Under the law, geographic restrictions on telestroke consultations will be eliminated in 2019; telehealth coverage in Medicare Advantage plans will expand under Medicare Part B in 2020, and Accountable Care Organizations will have greater freedom to use telehealth services.

Provisions in CMS’s 2019 Medicare Physician Fee Schedule would further support access to care using technology by expanding reimbursement for providers who evaluate certain store-and-forward data (for example, patient images), conduct brief, virtual check-ins to determine if patients need to visit in-person, and expand Medicare-covered telehealth services to include certain prolonged preventive services.

Recent HHS reports indicate high billing and coding errors among telehealth providers. With the OIG’s addition of telehealth payment audits to the 2018 Work Plan, providers need to be proactive in order to comply with regulatory and compliance requirements.

One key step is to review and update corporate compliance programs (particularly those covering billing, coding and documentation policies) to confirm proper billing for services and to show that compliance programs effectively prevent, identify and offer pathways to address billing issues that may arise.

Accordingly, it’s important to note that even though CMS recognizes value in expanded telehealth reimbursement, its primary focus is on Medicare’s bottom line.

While those excited about telehealth adoption may be somewhat disheartened by these cautions, the 30,000-foot view suggests a very positive trajectory. Reimbursement expansion for certain Medicare services and interest in telehealth’s role in achieving larger policy goals reflect Congress’s understanding that these are the future of healthcare.

Additionally, CMS’s expansion of telehealth-covered services, combined with the fact that Medicare and Medicaid payments for telehealth services are at an all-time high, indicate that telehealth reimbursement will continue to improve.

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