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OVERVIEW: Telehealth services finally makes its breakthrough in Medicare. The federal spending package finalized last night (errrr, early this morning) permits inclusion of telehealth services as a core benefit of Medicare Advantage, encourages home dialysis by permitting telehealth visits with nephologists and provides reimbursement for telehealth consultations for stroke victim. |
In June, we suggested that the bipartisan CHRONIC Act, which finally breaks down Medicare’s long standing opposition to paying for telehealth services on a large scale, would become law in 2017.
Ok, we were off my about 40 days. But we will take it.
The CHRONIC Act, now part of the Continuing Resolution, was approved by the House and the Senate this morning. A discussion of the all the major provisions of the bill can be found here. The most relevant portions of the CHRONIC Act, to us any way are:
Telehealth as Core Benefit in Medicare Advantage. For plan year 2020 and beyond, MA plans may provide any Part B service via telehealth provided it is medically appropriate. A plan that chooses to provide services via telehealth must also offer them in person.
Today, certain Medicare Advantage plans offer telehealth services as part of their supplemental benefits. The CHRONIC Act/CR makes telehealth services a core benefit of a Medicare Advantage plan. As such, Medicare Advantage plans would no longer have to treat telehealth services as supplemental benefit for enrollees.
Congress’ choice to expand telehealth services via Medicare Advantage reflects both a desire to prevent fraud, waste and abuse in the Medicare program while making Medicare Advantage plans more attractive to beneficiaries.
The absence of a physical encounter, like that which occurs in a telehealth visit, has always made the fine folks at the Center for Program Integrity nervous. By permitting reimbursement of telehealth services via Medicare Advantage plans only, Congress is assured of two layers of oversight - CMS’s monitoring of MA plans and the plans themselves.
This provision is just another brick on the load of an administrative policy that seeks to shift the majority of Medicare eligible individuals to a Medicare Advantage plan. An MA-friendly political environment, improvements to risk adjustment, especially for chronically ill patients, and improved convenience for beneficiaries all add up to expanded enrollment in MA plans.
Worth noting that in January, MA enrollment crossed the 20 million mark, over one third of eligible beneficiaries.
As a result of this change in law, we would expect TDOC – which already serves MA plans as a supplemental benefit – to expand its footprint with payers in 2018.
Other provisions of the CHRONIC Act support the expansion of telehealth services in care for dialysis and stroke patients but have less significant implications for TDOC and other telehealth platforms:
Extended access to home dialysis therapy. ESRD patients that use home dialysis will be able to choose a telehealth platform for their monthly assessment with a nephrologist effective Jan 1, 2019. The telehealth benefit is limited to once every three months and not available for the first three months of dialysis treatments. Telehealth technology can be provided to a dialysis clinic and a patient without triggering the anti-remuneration clauses of Medicare law.
CMS and Congress have made encouraging home dialysis a priority in an attempt to reverse 40 years of policy bias in favor of clinic-based care. In 2015, the GAO released a report suggesting CMS could alter Medicare payment policies to encourage home dialysis. For FY 2017, CMS increased the in-home training reimbursement and signaled they would increase it more if necessary.
Congress’ decision to expand telehealth services to monthly nephrology assessment places further emphases on home care.
Access to telehealth for stroke victims. Beginning in Jan. 1, 2019, geographical requirements for telehealth services paid for by Medicare shall not apply for diagnosing, evaluating or treating symptoms of acute stroke. Originating sites will be expanded at CMS’s discretion. However, no facility fee will be paid to newly added sites.
This provision reflects clinical advances in treatment of stoke that require immediate intervention. Those clinical advances have been difficult to realize in areas with access limitations like rural communities and congested urban environments. Medicare payment for telehealth services for treatment of stroke encourages adoption of clinical advances regardless of geography.
Call with questions.
Emily Evans
Managing Director
Health Policy
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