Medical practices innovate care delivery, increase telehealth access amid COVID-19 MGMA Stat - April 1, 2020 Operations Management Quality & Patient Experience Health Information Technology Sign in to save MGMA Staff Members The Medical Group Management Association’s most recent MGMA Stat poll asked medical practice leaders, “Has your practice expanded telehealth access amid COVID-19?” The majority (97%) responded “yes,” while 3% indicated “no.” The poll was conducted March 31, 2020, with 1,553 applicable responses. Medical practices and physicians of all specialties are facing new challenges, such as personal protective equipment (PPE) and staffing shortages, adverse financial impacts, and lack of testing resources, that directly impact the ability to care for patients, even if patient care is not related to COVID-19. Practices are adapting to meet the needs of their patient populations and considering innovative ways to ensure care continuity. With the new flexibilities provided by the Centers for Medicare & Medicaid Services (CMS), many in the physician community are turning to telehealth as a possible solution. In one week we moved almost 100% of primary care appointments to video/phone. Something to ponder. — BlackHillsJack (@ALASKANJACKSON) March 29, 2020 Following the passage of the Coronavirus Preparedness and Response Supplemental Appropriations Act and the Coronavirus Aid, Relief, and Economic Security (“CARES”) Act, Department of Health & Human Services (HHS) Secretary Alex Azar was given authority to waive certain Medicare telehealth restrictions, effective for the duration of the COVID-19 public health emergency. The following requirements for billing telehealth services through Medicare were waived: Geographic restrictions, permitting clinicians to furnish telehealth services to patients located in any geographic area [e.g., both non-rural and non-health professional shortage areas (HPSAs)]. Originating site restrictions, permitting clinicians to furnish services to patients in their homes. Telephone restrictions, meaning that telehealth services can be furnished via telephone or other qualifying device so long as the device has both audio and video capabilities. In addition, the HHS Office for Civil Rights (OCR) will exercise enforcement discretion and waive penalties for HIPAA violations against healthcare providers who serve patients in good faith through everyday communications technologies, such as FaceTime or Skype. CMS will also pay for telephone E/M codes (CPT codes 99441-99443 and 98966-98968). Prior to CMS’ interim final rule, these codes were not reimbursable under Medicare. Ordinarily, these codes are intended for established patients, but CMS is exercising its enforcement discretion and will not conduct reviews to consider whether these services were furnished to established patients. Access MGMA’s resource on Medicare Telehealth Waivers During the COVID-19 Pandemic The need for expansion of audio-only services As stated, the latest telehealth Medicare waivers are still quite restrictive. Audio-only capabilities are limited to lower-acuity visits with a maximum reimbursement of $41 for 21 minutes. “Not everyone has the luxury of broadband access and video hardware,” noted Anders Gilberg, senior vice president, MGMA Government Affairs, adding that these newly reimbursable telephone codes are not an equitable solution for patients or practices. A physician at a rural practice in Louisiana told MGMA, “It would be an understatement to say that my patients are lacking the latest technology. Many of my patients do not have internet or smartphone access and do not have the technical expertise to add video messaging to their phones or home computers if their devices would even be capable of adding such technology.” Mark Stephan, MD, MBA, chief medical officer, Equality Health, has worked with numerous small to mid-sized independent physician practices in implementing telehealth apps following the waiver implementation in March. He finds that basic phone visits are still needed for patients who have difficulty mastering video-and-audio technology. “This telehealth boom will help move the ball forward” for physician practices to respond to COVID-19, Stephan said, but he added that “any solution that sticks” should include audio-only services. “We all have to do our part to flatten the curve of the COVID-19 pandemic,” said the physician from rural Louisiana, “and releasing physicians from the video component of the telemedicine requirement during this national state of emergency would go a long way to help physician offices stay open and treat our most vulnerable patients without exposing them to unnecessary risk and the very real possibility of a death sentence.” MGMA continues to advocate for further telehealth flexibilities to expand audio-only services and ensure adequate reimbursement throughout the duration of COVID-19. What’s next for telehealth The Administration’s efforts to expand telehealth services under Medicare to date have led to many commercial payers following suit. This industry-wide expansion has significant potential to increase access, especially for patients with multiple chronic conditions who may need to see a physician during the outbreak, as noted by Gilberg on a recent MGMA Insights podcast episode. “You have instances where you may have a patient who has symptoms that maybe are not critical, where then they can use the technology to talk to a provider, and to get an assessment with a safe distance and in the comfort of their own home,” Gilberg said. “We don't want healthy, especially elderly, patients coming into the doctor's office, where they might be exposed to someone with the virus at a time when we can leverage technology and provide the same services.” Stephan noted that the COVID-19 pandemic is “the nudge the whole country needed” to embrace expanded telehealth services, but the best use case — especially during these times — is for better management of patients with chronic conditions. Those patients “are rightfully scared about coming in” to physician practice offices given higher risks associated with comorbid conditions. Ensuring these patients have an expanded means for check-ins and medical management activities will help protect them and a practice’s providers and staff members. “I’m hopeful that we see a gradual expansion of access in primary care,” Stephan said. “This is another big step in practice transformation.” Additional resources MGMA COVID-19 Action Center MGMA COVID-19 Resource Center Medicare Telehealth Waivers During the COVID-19 Public Health Emergency COVID-19: What healthcare leaders need to know about telehealth and the CMS policy changes Starting a telehealth program in your practice: Know the steps Would you like to join our polling panel to voice your opinion on important practice management topics? MGMA Stat is a national poll that addresses practice management issues, the impact of new legislation and related topics. Participation is open to all healthcare leaders. Results of other polls and information on how to participate in MGMA Stat are available at: mgma.com/stat.