{"id":19046,"date":"2020-04-19T22:30:05","date_gmt":"2020-04-20T02:30:05","guid":{"rendered":"https:\/\/avalere.com\/?p=19046"},"modified":"2022-10-31T11:44:14","modified_gmt":"2022-10-31T15:44:14","slug":"provider-impact-of-covid-19-telehealth-policies-by-specialty","status":"publish","type":"post","link":"https:\/\/advisory.avalerehealth.com\/insights\/provider-impact-of-covid-19-telehealth-policies-by-specialty","title":{"rendered":"Provider Impact of COVID-19 Telehealth Policies by Specialty"},"content":{"rendered":"

Including existing and temporary guidance, 191 physician procedure codes are currently eligible for reimbursement via telehealth<\/a>. These procedures comprise an estimated 33% of total Medicare FFS physician payments for the latest full year of data assessed, CY2018. For certain specialties, 90% or more of Medicare payments are eligible for reimbursement via telehealth, based on Avalere\u2019s assessment of commonly performed services per specialty.<\/p>\n

Additionally, major commercial payers are initiating coverage policy changes similar to Medicare, including adding codes to telehealth lists, expanding of telehealth partners, waiving originating site requirements, and waiving member cost sharing. Payers interviewed by Avalere generally expect a number of these flexibilities to continue into the future.<\/p>\n\n\n\n\n\n\n\n
Table 1: CMS Telehealth Codes and Corresponding Medicare FFS Physician Payments<\/caption>\n
CMS Category<\/th>\n# of Codes<\/th>\n% of Medicare Payments<\/th>\n<\/tr>\n<\/thead>\n
Existing 2020 Telehealth Codes<\/th>\n106<\/td>\n24%<\/td>\n<\/tr>\n
Temporary COVID Guidance<\/th>\n85<\/td>\n9%<\/td>\n<\/tr>\n
Total<\/th>\n191<\/td>\n33%<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

Source: CMS Covered Telehealth Services for PHE<\/a>, Avalere Analysis of Medicare Provider\/Supplier Procedure Summary File<\/em><\/p>\n

Existing and Temporary COVID Guidance for Medicare Telehealth Codes<\/h2>\n

Annually, CMS updates the list of telehealth services allowed to be furnished as well as policies that govern telehealth.<\/p>\n

As of March 30, CMS will now allow for more than 80 additional services to be furnished via telehealth. During public health emergencies, individuals can use interactive apps with audio and video capabilities to visit with their clinician for an even broader range of services. Providers can also evaluate beneficiaries who have audio phones only.<\/p>\n\n\n\n\n\n\n\n\n\n\n\n
Table 2: Telehealth Guidance Under Existing and Temporary Flexibilities<\/caption>\n
Telehealth Requirements<\/th>\nExisting Telehealth<\/th>\nTelehealth Flexibilities Under COVID-19<\/th>\n<\/tr>\n<\/thead>\n
Originating Site Requirements<\/th>\nWithin a rural health professional shortage area or in a county outside a metropolitan statistical area<\/td>\nNo limitations<\/td>\n<\/tr>\n
Originating Place of Service<\/th>\nPhysician office, hospital, CAH, rural health clinic, FQHC, SNF, community mental health centers, renal dialysis facilities, mobile stroke units, patient\u2019s home only for ESRD for home dialysis<\/td>\nAdds patient\u2019s home, nursing facilities, IRF, hospice, ER<\/td>\n<\/tr>\n
Equipment Requirements<\/th>\nHIPAA-complaint audio-visual equipment<\/td>\nAny audio-visual equipment or application<\/td>\n<\/tr>\n
Provider Type<\/th>\nPhysicians, NP, PA, Nurse-midwives, Clinical nurse specialists, CRNA, Clinical Psychologists, and Clinical Social Workers, Registered dietitians, Nutrition professionals<\/td>\nAdds physical therapists, occupational therapists, speech-language pathologists<\/td>\n<\/tr>\n
Patient Type<\/th>\nEstablished patients<\/td>\nNew and established patients<\/td>\n<\/tr>\n
Supervision<\/th>\nN\/A<\/td>\nGeneral supervision<\/td>\n<\/tr>\n
Payment Methodology<\/th>\nFacility payment rate<\/td>\nNon-facility payment rate when appropriate<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

Source: CMS Interim Final Rule, Medicare and Medicaid Programs; Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency<\/a><\/em><\/p>\n

Providers can bill for telehealth visits at the same rate as in-person visits. Telehealth visits include emergency department visits, initial nursing facility and discharge visits, home visits, and therapy services, which must be provided by a clinician that is allowed to provide telehealth. New as well as established patients may now stay at home and have a telehealth visit with their provider<\/p>\n

CMS is allowing telehealth to fulfill many face-to-face visit requirements for clinicians to see their patients in inpatient rehabilitation facilities, hospice, and home health. CMS is making it clear that clinicians can provide remote patient monitoring services to patients with acute or chronic conditions, as well as patients with only 1 disease. For example, remote patient monitoring can be used to monitor a patient\u2019s oxygen saturation levels using pulse oximetry.<\/p>\n

Medicare Advantage plans have also been granted increased flexibility regarding telehealth benefits through CMS finalized policies<\/a> regarding the use of telehealth diagnoses for purposes of risk adjustment calculations. CMS explained that COVID-19<\/a> related expanded use of virtual care made inclusion necessary.<\/p>\n

In addition, CMS is allowing physicians to supervise their clinical staff using virtual technologies when appropriate, instead of requiring in-person presence.<\/p>\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n
Table 3: CMS Permanent and Temporary Telehealth Codes by Category<\/caption>\n
Category<\/th>\nExisting Codes
\nJan 2020<\/th>\n		COVID Codes
\nMar 2020<\/th>\n		Total Codes<\/th>\n<\/tr>\n<\/thead>\n
Speech, physical, occupational therapy<\/th>\n0<\/td>\n20<\/td>\n20<\/td>\n<\/tr>\n
Home visit, new and established patients<\/th>\n0<\/td>\n15<\/td>\n15<\/td>\n<\/tr>\n
Observation and hospital care<\/th>\n0<\/td>\n12<\/td>\n12<\/td>\n<\/tr>\n
Pediatric and neonatal care<\/th>\n0<\/td>\n11<\/td>\n11<\/td>\n<\/tr>\n
Psychiatry and psychotherapy<\/th>\n14<\/td>\n9<\/td>\n23<\/td>\n<\/tr>\n
Emergency department visit, critical care<\/th>\n0<\/td>\n7<\/td>\n7<\/td>\n<\/tr>\n
Nursing facility care<\/th>\n4<\/td>\n5<\/td>\n9<\/td>\n<\/tr>\n
ESRD services<\/th>\n18<\/td>\n3<\/td>\n21<\/td>\n<\/tr>\n
Health and behavior assessment, intervention<\/th>\n12<\/td>\n2<\/td>\n14<\/td>\n<\/tr>\n
Radiation therapy<\/th>\n0<\/td>\n1<\/td>\n1<\/td>\n<\/tr>\n
Patient risk assessments<\/th>\n2<\/td>\n0<\/td>\n2<\/td>\n<\/tr>\n
Nutrition counseling<\/th>\n4<\/td>\n0<\/td>\n4<\/td>\n<\/tr>\n
E&M Codes<\/th>\n10<\/td>\n0<\/td>\n10<\/td>\n<\/tr>\n
Subsequent observation care<\/th>\n3<\/td>\n0<\/td>\n3<\/td>\n<\/tr>\n
Subsequent hospital care<\/th>\n3<\/td>\n0<\/td>\n3<\/td>\n<\/tr>\n
Prolonged service codes<\/th>\n6<\/td>\n0<\/td>\n6<\/td>\n<\/tr>\n
Smoking, alcohol, opioid treatment<\/th>\n11<\/td>\n0<\/td>\n11<\/td>\n<\/tr>\n
Care planning and management<\/th>\n8<\/td>\n0<\/td>\n8<\/td>\n<\/tr>\n
Telehealth consultation (various)<\/th>\n9<\/td>\n0<\/td>\n9<\/td>\n<\/tr>\n
Observation or hospital care<\/th>\n2<\/td>\n0<\/td>\n2<\/td>\n<\/tr>\n
Total<\/th>\n106<\/td>\n85<\/td>\n191<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

Source: CMS Covered Telehealth Services for PHE<\/a><\/em><\/p>\n

Impact by Specialty Varies in Terms of Procedures Utilized<\/h2>\n

Avalere analysis of Medicare data illustrates that, for certain specialties, 90% or more of historic Medicare FFS payment would be eligible for telehealth payment based on new COVID telehealth flexibilities.<\/p>\n