As we say in politics, a good crisis is a terrible thing to waste.
Using emergency powers, Medicare will begin paying for office, hospital and other visits furnished via telehealth to a wide range of providers without restriction, effective as of March 6, 2020.
In the absence of this emergency waiver, traditional Medicare could only pay for telehealth on a limited basis. A Medicare enrollee had to reside in a rural area and conduct the telehealth visit at one of several originating sites like a nursing home or a hospital.
As you might guess, Medicare telehealth law and regulation predate the release of Iphone 1.
The Trump administration has been a strong advocate of telemedicine. In 2019, it adopted rules that permitted Medicare reimbursement for brief check=ins – short patient-initiated communications – and E-visits through an online patient portal.
Effective for services rendered beginning March 6, 2020, Medicare will now pay for three types of telehealth visits:
- Medicare Telehealth Visits. These visits will be the telephonic equivalent of an in-person E/M visit (CPT Code 995) a physician. The physician will be paid for professional services at the same rate as an in-person visit (about $50-$75 depending on time spent). Providers may waive the cost-sharing requirements under a waiver by the Office of the Inspector General.
- Virtual Check-ins. Established Medicare patients throughout the country can have brief communication with their doctor through synchronous method including the telephone. Applicable HCPCS Codes are G2012 and G2010.
- E-visits. Communication initiated by the patient through the doctor’s portal are considered E-visits. (CPT Code 993 and HCPCS Code G2016-G2063)
Importantly, the Office of Civil Rights has agreed to exercise enforcement discretion and waive penalties associated with violations to HIPAA. This move will allow providers to serve patients through non-secure technologies like Facetime and Skype during the health emergency.
Health care is slow to change, this much we know. But we cannot help being reminded of the NYC transit strike when women shed their heels and started walking to work in white socks and sneakers. Something they continue to do to this day.
Will the emergency last long enough to alter the use of telehealth service by physicians and patients? While life is likely to return to normal sometime this summer, the emergency declaration may continue beyond that.
What we find most interesting is how relaxing of rules will change the perception of telemedicine as an outsourced solution in some cases, or as competing virtual practices in others. Once, the use case is established for physicians, assuming fraud does not become rampant, do they simply adopt use of electronic communication in much the same way the banking industry adopted the computer?
Changes would have to become permanent, which if the experience if a positive one for the patients, providers and the taxpayer, seems like a possibility like never before.
In that event, the future state of TDOC become more uncertain not less. In the meantime, they are the most viable response to the current circumstances.
Emily Evans
Managing Director – Health Policy
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