Telehealth Rises in Response to COVID-19

A closer look at telehealth's importance during the pandemic 

Telehealth encompasses a broad range of services, including live video chats with patients, remote patient monitoring, store-and-forward transmission of diagnostic images or laboratory results, and telepharmacy services. Telemedicine, meanwhile, refers to a subsection of telehealth that deals with remote clinical services. Each of these services must use HIPAA-compliant software.

In a September 2019 blog, I described the potential for telemedicine to help overcome the biggest challenges in Medicaid programs, cost and access to care.

Telehealth Today

Due to the challenges that COVID-19 presents, the Centers for Medicare and Medicaid Services (CMS) and state Medicaid agencies are ramping up guidance and support of telehealth services. Such services enable practitioners to interact with patients and relevant information without risking exposure to a highly contagious pathogen during the global pandemic.

In the current state of affairs, telehealth offers numerous advantages. Under the Center for Disease Control’s (CDC) social distancing recommendations and various governmental authorities’ stay-at-home and shelter-in-place orders, telehealth provides healthcare access that is safer for patients and protects public health. Further, healthcare providers who may have been exposed to the virus and need to self-isolate can continue to provide care from their homes.

For Medicare beneficiaries, telehealth services were temporarily expanded to include more types of services across the nation beginning March 6, 2020, through the duration of the COVID-19 public health emergency. Previously, Medicare would only pay for routine visits and check-ins in rural areas. Telehealth services are paid using the Medicare Physician Fee Schedule at the same rates as in-person services, though Medicare coinsurance and deductibles still apply.

Medicaid agencies already had broad authority to implement and regulate telehealth services before the crisis. Further, the various medical billing codes to identify, track, and reimburse telehealth services are already in place. While each state has a different approach to and scope for telehealth services, most if not all Medicaid agencies are highlighting this aspect of their programs by reinforcing existing policies and issuing emergency orders to expand telehealth services.

State Medicaid Telehealth Guidance

New York, which expanded its telehealth services in 2019, issued guidance to Medicaid providers effective March 1, 2020 that sets reimbursement for telehealth services at the same rates as in-person visits and expands services to include telephone-only visits when audiovisual technology is not available at either the originating site (where the patient is located) or the distant site (where the provider is located). During the state of emergency, there is no limit on where the New York Medicaid member or provider is located, and both can be out-of-state.

Other states have taken steps to bolster telehealth services during the crisis.

• Illinois expanded telehealth originating sites to include a patient’s place of residence within the state or a temporary location out of state under its §1135 waiver on March 9, 2020.
• North Carolina modified its tele psychiatry guidance to include associate-level providers including licensed clinical social worker associates and licensed marriage and family therapist associates. The state also expanded the list of psychotherapy codes that can be billed as telemedicine visits.
• The Washington State Health Care Authority expanded its list of behavioral health codes that can be billed to include telephone and online evaluation and management. The state authority also expanded reimbursable telehealth services to include physical, occupational, and speech therapy (PT/OT/ST). Telephone-only delivery is not reimbursable for PT/OT/ST codes, though telephone assessment of progress is reimbursable.
• The Ohio Department of Medicaid issued an emergency rule that allows Medicaid beneficiaries to receive medical or behavioral telehealth services regardless of their last in-person visit and regardless of whether they are an existing patient, which were both previously required. The new rule also expands the list of provider types that can bill for telehealth services, allows for Medicaid billing regardless of the originating or distant sites (except for penal facilities), and expands the types of services covered.
• New Hampshire Medicaid expanded its telehealth policy to reimburse for audio-only services because previously live audiovisual was required. The state also removed restrictions on originating sites to include private residences, and now pays the same rate as if the service was provided in person.
• The Missouri HealthNet Division is waiving the requirement that patients be established prior to receiving telehealth services, is allowing use of telephone-only services, is allowing quarantined providers working at alternate distant sites to continue to provide telehealth services and to bill using their provider number, and is allowing out-of-state providers to provide telehealth services to MO HealthNet beneficiaries as long as they are licensed in the state where they practice.

While state Medicaid programs are tackling the ramp up of telehealth options in their own ways, a few commonalities are emerging. The relaxing of rules regarding telehealth is currently being done under emergency authority on a temporary basis. Restrictions on originating and distant sites have been modified or removed. Where audiovisual technology was previously required, a telephone call will often now suffice. In addition, the list of medical and behavioral health services patients can access from their own homes has expanded. For the foreseeable future, telehealth is rising from a niche healthcare sector used to serve narrowly defined populations in specific ways, into a primary method for people across the nation to access a broad range of healthcare services.