How Quality Standards will be Measured for Telehealth

At a recent Maryland MGMA event I sat in on an intriguing lecture entitled “The Future of Big Data in MIPS, APMs and MACRA in Maryland”. I was overwhelmed by the plethora of acronyms, statistics, regulations, and comparisons. It was easy to get lost in that sea of numbers, and I knew they were only scratching the surface of the topic. But I soon realized how vital that information is for the success and future of healthcare in general, and telehealth specifically. So, for those that are only lightly following Medicare reform, or are in the early part of their understanding of data analytics in healthcare (as most of us are), the high-level, dumbed-down version is this: the way consumers make choices about healthcare and the way practitioners get paid for the services they provide is changing.       The amount of public data about individual physicians, as well as hospitals and medical centers, is mounting steadily. Information on quality outcomes such as rehospitalizations and surgery complications is easily accessible, as well as interesting tidbits on how much money physicians are receiving from pharmaceutical companies and how many prescriptions they are writing. Also being made public is the cost of procedures and services at various institutions and offices – there is even a push for drug costs to be stated on ads. All of this is beginning to factor more in how the public is choosing how they get their health care – and who from. Along with that, Medicare is implementing a change, starting this coming year, switching from basic fee-for-service, to payment based on outcomes. While this process was begun in 2015 with meaningful use, and has since morphed into the Merit-based Incentive Payment System (MIPS). This coming year the percentages and amounts and all of those difficult-to-understand algorithms are changing to make it so that, moving forward, it will be almost impossible for physicians to stick with the old fee-for-service payment module and stay out of the red. Medicare is making a strong push to almost require physicians to change to an advanced Alternative Payment Module (aAPM) in which the provider assumes varying degrees of risk and the Medicare payments are calculated based on a range of quality and care outcomes. The one piece of good news in all this is, after the passing of the Bipartisan Budget Act of 2018, practices that sign on to participate in a payment module that assumes two-way risk will be able to take advantage of the telehealth waiver that used to only apply to select ACOs. This waiver eliminates the geographical and originating site restrictions that CMS has historically put on telemedicine, thus making it finally possible to use telemedicine in a way that can benefit a wider patient base – not just the special-use cases that had previously been the only acceptable application of the technology to Medicare. And the rest of the healthcare industry will follow, as Medicare has long been the low-bar-setter in this field. As we look forward to these changes beginning to take place, however, we realize a piece to the puzzle is missing – quality metrics for telemedicine. How do we judge how well we are doing? More importantly in some ways (for your paycheck, for example), how will Medicare and other payers judge you? There are some standards and guidelines that have been published – the American Telemedicine Association and American Psychiatric Association just jointly released their guide on best practices for telemental health, one of the most promising applications of telemedicine, especially in the current Opioid Crisis. The ATA has also, over the past 5 years, released other guidelines and standards for various elements of and common use-cases for telemedicine. As of now, though, there are no distinct, measurable quality and outcome standards to which Medicare and the various other payers can refer when creating the new reimbursement policies that are desperately needed and have been the biggest obstacle to instituting telemedicine programs in practices nationwide. Thankfully, that work has begun. The National Quality Forum released a report last year entitled “Creating a Framework to Support Measure Development in Telehealth” as the culmination of their Telehealth project which does exactly that. In September of 2018 the ClearHealth Quality Institute, the only independent accrediting agency recognized by the ATA, started to develop standards measures for telehealth outcomes, which are now available to purchase on their website, with standards for Mental Health Parity Accreditation coming soon. We are moving forward, folks. And, for those who recognize that the future of and maximum benefit from telemedicine lies in the direct-to-patient delivery model, there is hope on the horizon. As more government payment systems remove the archaic geographical and originating site restrictions and more states create parity laws, payers across the board will be forced to accept that telemedicine is just as much a central and necessary part of our healthcare landscape as conventional delivery systems, and freeing access to it will only benefit the nation’s health profile as a whole.
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