CMS' latest draft of the 2019 Physician Fee Schedule and Quality Payment Program creates ample opportunity for telehealth in Medicare.
Under the current Medicare program, only live-video conferencing telehealth services under specific circumstances that account for where the patient lives — rural or nonrural — are reimbursed.
Because a number of telehealth services only apply to patients in rural areas, CMS developed remote patient monitoring codes to provide a fixed monthly reimbursement for the remote collection and interpretation of patient data. In other words, providers may only be reimbursed once per month for analyzing data collected by their patients' devices, explains Sebastian Seiguer, the CEO of mobile health company emocha.
Moreover, Medicare frequently changes its list of approved telehealth services, some of which include emergency department consultations, outpatient visits and nutrition therapy. However, in terms of non-face-to-face asynchronous remote monitoring, CMS only reimburses care for patients with chronic illness; for other services, this type of store-and-forward telehealth is non-reimbursable — aside from beneficiaries in Alaska and Hawaii.
Under CMS' proposed revisions to the rule, the telehealth services Medicare reimburses would vastly expand. Telehealth visits would cost Medicare less — "Medicare would pay $14 per visit in the first year for these communication technology-based services, compared with $92 per visit for the corresponding established patient visits," according to the proposal — and Medicare would cover more types of telehealth.
"The proposed rule offers an entirely new framework for telehealth reimbursement," Mr. Seiguer said.
Becker's Hospital Review spoke with Mr. Seiguer, who explained the proposal and its implications.
Editor's Note: Responses have been lightly edited for brevity and clarity.
Question: How does CMS' proposed rule change expand telehealth reimbursement?
Sebastian Seiguer: Rather than focus on the specific use cases, it provides broad reimbursement for two types of communications technology: (1) live video and audio interactions when used by a physician or other health professional to assess a patient's condition and decide whether the patient needs an appointment, and (2) asynchronous, which encompasses non-live patient-recorded video or images used by a physician or other health professional to assess a patient's condition.
CMS wants to make sure that these check-ins are independent evaluations, and not related to other appointments. As such, reimbursement does not apply to a series of evaluations that are related and take place within specified time frames before and after reimbursed appointments.
Q: Why is it important that asynchronous telehealth be reimbursed?
SS: Asynchronous telehealth is critically important for several reasons, including patient and provider convenience, connectivity limitations of live-streaming video interactions and efficiency.
For example, in the U.S., every public health department is required to provide directly observed therapy to patients with tuberculosis. This requires a healthcare worker to observe patients as they take every dose of medication on a near daily basis, for six to nine months. While some jurisdictions have tried to do this using live-streaming videos, many have had tremendous difficulty and have opted to implement asynchronous video solutions instead.
Consider that a typical, large city may have 30 to 100 patients with TB at a time. For a five-day per week regimen, this would require 20 appointments per month per patient, or several thousand appointments for all their patients during a six-month period. Using asynchronous video recordings, patients take their medication at any time of day, and providers review that data the next day at their convenience. Recent National Institutes of Health-funded studies by Baltimore-based Johns Hopkins University and the state of Maryland demonstrated that an asynchronous telehealth solution can save thousands of dollars per patient.
The proposed code — GRAS1 — creates flexibility using technology in many ways to support patients and deepen the connection between patients and their providers in between visits. CMS clearly states that this can be accomplished through pre-recorded still or video images. There is tremendous potential to leverage mobile health solutions to ensure that patients are adhering to treatment in ways that were never before possible due to logistical burdens and time constraints. Providers can use asynchronous video technology to check in with patients for anything from making sure a patient with asthma is using his or her inhaler properly to confirming that patients with hypertension are taking every dose as prescribed to help avoid health complications.
Q: How does the proposal affect remote patient monitoring technologies?
SS: Information from devices such as heart rate monitors or other devices will continue to be reported with existing CPT codes for remote patient monitoring. The proposed rule contained few additional CPT codes in this regard.
Q: What about other forms of patient-generated health data? Can Medicare beneficiaries submit this information as part of a virtual check-in?
SS: While data collected by patients using devices — known as remote patient monitoring — was not the focus of this rule, comment was requested for the possibility of using communication technology to improve Medication Assisted Treatment for opioid addiction. CMS proposes creating a "bundled episode of care" that incorporates communication technology for components of MAT, such as counseling, medication management and observed drug dosing.