News and Notes on Telemedicine Innovation

With the demand for telehealth services skyrocketing, many providers who were not planning on adding virtual care to their service offerings have had to quickly implement and deploy brand new teachnology. That takes money, at the most economically uncertain time of our generation. Knowing this, the government has enabled the Department of Health & Human Services to create grant programs to meet these needs. Read about the various programs on their site. The Federal Communications Commission has also created a COVID-19 Telehealth Program, which draws from the $200 million set aside for telehealth funding as part of the CARES Act. This is available for both rural and non-rural medical providers.

HHS Coronavirus Page
FCC COVID-19 Telehealth Program Application Guidance

It has been estimated that 93% of healthcare services have been delivered remotely during this pandemic. While this an amazing time for growth and innovation, for those areas of the country without access to internet it can be scary and dangerous. Realizing this, the government has taken steps to quickly increase broadband access. Read about the new program from the Federal Communications Commission on their website.

FCC COVID-19 Telehealth Program

Many of our resources are from the Center for Connected Health Policy, which serves as the National Telehealth Policy Resource Center. True to form, they have created and are maintaining and up-to-date tracking page for all state actions regarding the global pandemic and national public health emergency.

CCHP COVID-19 Related State Actions

The Centers for Medicare & Medicaid Services has stepped up to the plate during this crisis and blown the doors wide open on their coverage and reimbursement requirements for telehealth services. This many changes however, can cause a massive amount of confusion for providers. Below is the list of waivers that have been realeased, as well as their COVID-19 page with a full list of their resources.

COVID-19 Emergency Declaration Blanket Waivers for Health Care Providers

CMS Current Emergencies Page

While private insurance policies vary across the country, many companies have established blanket telehealth coverage policies lasting for the period of the public health emergency. Industry trade association and policital advocay group America’s Health Insurance Plans has gathered all the relevant changes in one place.

AHIP’s Health Insurance Providers Respond to Coronavirus

With the massive amount of changes taking place, the already-confusing process of coding your medical encounters and services and submitting the bills for reimbursement has been rendered even more complex. We look to the experts for guidance, with daignosis codes from CDC and guidelines from the American Medical Association on procedural coding below.

CDC’s ICD-10-CM Official Coding and Reporting Guidelines

AMA’s CPT COVID-19 Coding and Guidance

Medicare is one of the largest providers of health insurance in the country, and many people rely on it to be able to afford medical services in a variety of specialties. They also have a very complicated reimbursement process, with very specific requirements for when they will cover services delivered through telehealth. View our resource page at the link below, with information taken from the Telehealth Resource Center’s informational booklet on the subject.

Medicare Telehealth Reimbursement Resource Page

The Center for Medicare and Medicaid Services only covers telehealth services when the service beneficiary is located in specific geographic areas. The CMS resource booklet defines that type of area as: “a county outside of a Metropolitan Statistical Area (MSA); OR a rural Health Professional Shortage Area (HPSA) located in a rural census tract”. The Health Resources and Services Administration provides two tools to assist providers in determining if their chosen originating site lies within one of those areas for the purpose of reimbursing telehealth services.

Medicare Telehealth Payment Eligibility Analyzer Healthcare Practitioner Shortage Area Analyzer

Every year, CMS publishes a list of CPT & HCPCS codes that they will accept on claims for reimbursement of telehealth services. They also accept requests for the consideration of two types of new codes to be added to that list for the next year: Category 1, which include services that are similar to items that are currently on the list of telehealth-acceptable codes; and Category 2, which are services that are not similar to the current list of telehealth-acceptable codes. The list of codes from the current year and previous year is available on the CMS website.

List of codes for telehealth services listed in the Medicare Physician Fee Schedule

In the middle of each year, CMS starts working on it’s Physician Fee Schedule for the next year. They will propose it, accept comments, make revisions, and then publish it by November of the year before it goes into effect. Telehealth is such a dynamic field, with advances and innovations occuring monthly, so every year there are changes to the particular section more than most others. Below you can find the most current PFS. The Center for Connected Health Policy also puts out an Infographic and Fact Sheet for those who want a quick version or easy-to-understand explanation of those changes.

CMS Physician Fee Schedule for CY 2019
CCHP 2019 PFS Infographic
CCHP 2019 PFS Fact Sheet

Each year there are more and more laws passed and regulations approved that advance the accessibility and practicality of using telemedicine in everyday medical practices. The Center for Connected Health Policy has an interactive map and searchable tracker designed to help you easily look up and access the current and pending legislation and regulations in any state that pertain to all aspects of telehealth. 

CCHP’s Current State Laws and Reimbursement Policies

CCHP’s Legislation and Regulation Tracking

While there are many ways to get paid for offering medical services via telehealth, perhaps the most common and desired one is through a patient’s individual insurance plan. These private payers are regulated by state laws that tell those companies the minimum they are required to cover in terms of services. Each state, however, has the ability to write these laws as they see fit. These are called “parity” laws, where the states require private payers offering commercial plans in their state to cover or reimburse for telemedicine services the same as they would for the same service delivered via in-person or face-to-face delivery, with a wide spectrum of conditions and caveats. To see whether your state has enacted parity legislation, see our map at the link below, taken from the American Telehealth Association website.

States with Parity Laws for Private Insurance Coverage of Telemedicine (2018)

Getting reimbursed for telehealth services through Medicaid is tricky, as each state has its own law governing what is covered and how it’s reimbursed. On top of that, every year there is more and more legislation passed at the state level affecting telehealth and Medicaid policy. Stay on top of the most current information by reading the Center for Connected Health Policy’s State Telehealth Laws & Reimbursement Policies Report. They have also presented the included information in an easy-to-read Infograph.

CCHP 50 States Policy Report:
PDF
Infograph

Everyone wants to get paid, but not everyone knows the ins and outs of medical coding. Telehealth is also such an emerging field, full of changes and advances all the time, and the procedures and expectations for how those services will be coded on bills to payers change frequently as well. We have developed a quick primer covering the basics of telehealth coding in the current insurance environment – click the link below!

Telehealth Coding 101

Practicing medicine in any capacity requires being up-to-date on the latest licensing policies in the state where you are located, and telemedicine is no exception. Licensing requirements and guidelines are regulated by state Medical Boards. The Federation of State Medical Boards keeps track of the regulations in each state, and has a helpful 50-State Telemedicine Policies overview as a quick-reference resource for physicians who may be asking this question.

FSMB 50 State Telemedicine Policies Overview

One of the biggest benefits of telemedicine technology is the ability to provide medical services to anyone, anywhere. This is also one of the greatest barriers to physicians wishing to extend their practice across state lines – most reimbursement laws and rules require the physician to be licensed in the state where their patient is located. To address this obstacle, many states have opted to enter into an agreement with other participating states to create a common language and a standard of regulations in order to have one medical license that is valid in any of the participating states. This is now called the Interstate Medical Licensure Compact, and during each legislative session, more and more states are enacting legislation to join this agreement. To see if your state is one of them, check the interactive map on the ILMCC website, which provides current information on where each of the 50 states is in the process of adopting this compact.

Interstate Medical Licensure Compact 50 State Legislation Status Map

Along with physicians, there are other types of providers for whom telemedicine has many advantages, and the licensing difficulties affect them as well. To address this, more and more licensing boards for various types of providers are following the example of the Interstate Medical Licensure Compact by creating their own interstate compacts. Currently, there are compacts active and live for Registered Nurses, Physical Therapists and EMS Personnel. There are two more compacts, one for licensed psychologists and one for Nurse Practitioners, that have been enacted but are waiting for a certain number of states to join before they go live. To see where your state is in the process of adopting any of these compacts, see the following pages for state-specific maps and information.

Enhanced Nurses Licensure Compact (eNLC) Map & Implementation Dates:
MapList

Physical Therapy Licensure Compact

Recognition of EMS Personnel Licensure Interstate CompAct (REPLICA)
Psychology Interjurisdictional Compact (PSYPACT)

Legislative Tracker Advanced Practice Registered Nurses (APRN) Compact Information

Healthcare for veterans is an important field of medicine. Travel to speciality clinics for veterans is often more difficult than for others, and to this end, the US Dept of Veteran Affairs has a list of specialties that are approved and covered for the use of synchronous video telemedicine services. Their website lists those specialists, as well as has many helpful links for other aspects of their telehealth policy.

VA Real-Time Clinic Based Video Telehealth 

In almost every other sector of telemedicine, the barrier of cross-state licensing is an opposing one that is seeing some progress towards being eliminated, but slowly. However, as of June 11, the US Department of Veterans Affairs went live with a new rule that allows VA practitioners to see any patient anywhere in the country, regardless of state licensing laws, which is a large part of their “Anywhere to Anywhere VA Healthcare” Initiative. To read the full text of the new law, you can click the link below.

Department of Veterans Affairs Authority of Health Care Providers to Practice Telehealth

The Health Information and Portability and Accountability Act is one of the major players in determining policy for medical providers in all areas of practice. Telehealth is no different. As use of telehealth technologies becomes more common and widespread, practices must be careful to make sure that their policies comply with the regulations set forth in the Act. The National Consortium of Telehealth Resource Centers has published a helpful fact sheet to help you along on your quest for compliance.

National Consortium of Telehealth Resource Centers’ HIPAA & Telehealth Fact Sheet

The Center for Connected Health Policy has published a wonderful document that succinctly sums up the HIPAA regulations that affect telehealth.

CCHP’s HIPAA and Telehealth Fact Sheet

Prescribing and medication management already has so many restrictions and regulations surrounding it, and combining it with the relatively new practice of telemedicine only complicates it more. While legislators are still figuring out some of the details of the topic, there are some resources out there. The RUPRI Center for Rural Health Policy Analysis published a Rural Policy Brief on Telepharmacy in 2017 that, though some things may have changed, is a good place to start.

Telepharmacy Rules and Statutes: A 50-State Survey

The response most would have to that question is likely “I didn’t know there was a difference!” However, there is one, and it’s important. According to the Center for Connected Health Policy:

Online prescribing or internet prescribing: when a provider prescribes a drug to a patient based upon an interaction that has taken place online.

E-Prescribing: the act of a provider sending a prescription electronically to a pharmacy, such as through an EHR.

Full Downloadable Resource Coming Soon!

Historically, this has been one of the trickiest parts of prescribing medications through virtual care. Slowly but surely, states are getting wise to the benefits of telehealth and putting laws in place to allow this, but still protect against those who would abuse it and use the privileges fraudulently. The American Medical Association has a wonderful chart of each State’s laws regarding the patient -provider relationship and telemedicine.

AMA 50-state survey: Establishing the patient-physician relationship via telemedicine

Analysis & Update Coming Soon!

The world of telehealth reimbursement can be confusing and difficult to navigate and understand. At times there seems to be an entirely new language you need to learn just to get paid! To that end, the American Telehealth Association has published two resources to provide clarity to those seeking to understand this new frontier of medical practice. See their Telehealth Glossary and their Telehealth Definition Framework, which is a joint project between the ATA and the Telehealth Resource Center that seeks to provide a set of basic definitions for the terms used to describe these services that can be used to create cohesion across states and forums.  

ATA Telehealth Glossary ATA/Telehealth Resource Center Telehealth Definition Framework

If you are in the process of implementing a telehealth program in your practice, you will invariably come to the point where you ask yourself, “Am I doing this right?” Thankfully, various professional organizations have published their own versions of guidelines for and standards of practice for telehealth programs.

The Federation of State Medical Boards’ Model Policy for the Appropriate Use of Telemedicine Technologies in the Practice of Medicine

American Psychological Association Guidelines for the Practice of Telepsychology

American Academy of Ambulatory Care Nursing Telehealth Nursing Practice Scope & Standards of Practice (costs $29 for members / $44 for general public)

The American Telehealth Association has published a series of guidelines for implementing telehealth in different scopes of practice. Standards and guidelines have been proven through multiple studies to enhance outcomes and the success of telehealth programs in physician practices; finding one for your field could make all the difference for you. To access these guidelines you must be a member, but the process is easy and free of cost.

ATA Practice Guidelines & Resources

Looking to get more region-specific information about telehealth in your practice’s area? The National Consortium of Telehealth Resource Centers has an easy to use interactive map, showing which states belong to which region and linking to the regional telehealth resource center for each one.

NCTRC Find Your TRC Map

The National Consortium of Telehealth Resource Centers includes Resource Centers for each region of the United States. Most of them have published a best practices and general policy guide for their region. Click on your state or region below to find your Guide.

California TRC – Reimbursement

California TRC – Best Practices

Northwest Regional TRC (WA, OR, ID, UT, MT, AK) – Reimbursement

Great Plains TRAC (ND, SD, MN, ME, IA, WI) – Reimbursement

Great Plains TRAC (ND, SD, MN, ME, IA, WI) – Start-up Guide

Heartland TRC (MO, OK, KS) – Rules & Regulations

TexLa TRC (TX, LA) – Best Practices

The Center for Connected Health Policy keeps an updated page where they have PDF tracking reports for all state policy changes grouped by Telehealth Resource Center regions.

CCHP’s Legislative/Regulatory Update Resource Page

Over the past few years, many departments within the federal government have offered a variety of grants and incentive programs for medical practices wanting to implement telemedicine, in the hopes of increasing ease of access to medical care for our citizens. The Office of the National Coordinator for Health Information Technology at HealthIT.gov has a helpful guide of those departments, how they support implementation, and where you can find each program’s specific information. The National Consortium for Telehealth Resource Centers also offers a fact sheet on federal telehealth funding – it is a great overview of the kinds of funding available.

Federal Telehealth Compendium

NCTRC’s Funding Sources for Telehealth Fact Sheet

While it’s great to find out that there are opportunities for funding from other places besides your own pocketbook or profits, the process to getting to those funds can be long and complicated. The Great Plains Telehealth Resource & Assistance Center has a set of tips for grant writing to start you off.

GPTRAC’s 10 Tips in Writing Grant Applications

The cornerstone of implementing a new telemedicine program in any practice is making sure you make the right choices for which technology you utilize. The National Telehealth Technology Assessment Resource Center (TTAC) has many easy-to-access Toolkits for the various types of technology a  practice might need in the process of implementation, including Home Telehealth.

TTAC Technology Toolkits

While the idea of telemedicine might just seem intuitive to many, as with any new technology or process, there can be a learning curve. Training programs and resources can make or break the success of your telemedicine program. To help you get started, the NRTRC has published a white paper on the subject. The TexLa TRC also has a collection of training videos on a variety of topics that are helpful.

NRTRC’s Telehealth Network Training

TexLa TRC’s Telehealth Training Videos

While the benefits of offering telemedicine in any given practice have become increasingly obvious and necessary in this competitive market, sometime the thought of starting that process seems overwhelming. Again the National Consortium of Telehealth Resource Centers has come to your aid with a concise guide to implementing a telemedicine program in a practice, broken down into 15 steps. AMD Global Telemedicine, a pioneer of international clinical telemedicine technology, has also published a useful guide for implementing a successful telemedicine program, commissioned by the International Society for Telemedicine and e-Health, that gives more useful pointers on how to make this new venture work for your practice. TexLa TRC has an informative white paper on all aspects of implementation. Lastly, California’s Telehealth Resource Center has put together a Kit to help you develop your program today!

NCTRC’s 15 Key Steps for Creating a Business Proposal to Implement Telemedicine

AMD Global Telemedicine’s 10 Critical Steps for a Successful Telemedicine Program

TexLa TRC’s Implementing Telemedicine Service Operations

CTRC’s Telehealth Program Developer Kit

So, you’ve started the process of implementing telemedicine in your practice – now you need to let your patients know, as well as all the potential patients looking for a provider with a good telemedicine program. The California Telehealth Resource Center has published a wonderful guide to creating a marketing strategy for that purpose, easily adapted to a variety of clinical settings. The Northwest Regional TRC also has published a white paper on how to market your new telehealth program, as well as a Marketing 101 toolkit presentation.

CTRC’s Developing a Marketing Plan: A Step-By-Step Guide

NRTRC’s Marketing Your Telehealth Program

NRTRC’s Telehealth Marketing 101

http://www.americantelemed.org/home

The American Telemedicine Association truly is the leading source of information on all things telehealth, providing information on education, news, policy, and best practices, to name a few. There are many exclusive member benefits, including access to guides, publications and webinars, and membership is free of cost. This site is a must-visit for any provider starting on their telehealth journey.

http://www.cchpca.org/

The Center for Connected Health Policy calls itself “The National Telehealth Policy Resource Center” and it truly lives up to that designation, providing a wide variety of information on telehealth policy statutes, barriers and advancements on the state and federal level.

https://www.telehealthresourcecenter.org/

Did you know that there are telehealth resource centers for every state in America? These provide region-specific resources and information, as well as in-person help, on any subject you can think of relating to telehealth and starting a telemedicine program in your practice. The National Consortium of Telehealth Resource Centers will help you connect with your region’s Resource Center. The site also has resources like webinars, fact sheets, guides, checklists, and templates, among many others, to help you as you establish your telemedicine program.

http://ctel.org

If you have any questions about the legal aspects of starting and maintaining a telehealth program, this is your go-to site! They have real people you can call to help answer your questions, as well as published resources, webinars, and a large number of articles on a variety of topics.