March 20, 2020


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In response to the COVID-19 public health emergency, telehealth services are temporarily available to many more Medicare patients than before the pandemic. These services could provide lifesaving care during this time when Americans are strongly encouraged to limit face-to-face interactions to prevent transmission. The recent COVID-19 emergency funding law, included this temporary emergency section 1135 waiver to allow broader reimbursement of telehealth services.

Before the new law, telehealth services in Medicare were only available under limited circumstances, mostly for patients located in rural areas who traveled to local medical facilities to meet with practitioners at a separate physical location. Effective March 6, 2020, and for the duration of this national public health emergency, Medicare will pay for telehealth services without many of these restrictions.

Just this week, CMS released details describing how the telehealth waiver works and how it compares to other available telemedicine services, such as virtual check-ins and digital visits.

New Telehealth Waiver
The telehealth waiver covers a range of services delivered by a practitioner through telecommunications technology to Medicare patients in their homes or local medical facilities. Reimbursable services include evaluation and management, mental health counseling, and preventive care screenings. Elderly and medically compromised Medicare patients are among the most susceptible populations to the effects of COVID-19 and this telehealth option could help to prevent further risk to their health by traveling to a health facility to receive services. Telehealth services could also protect our health care workers from exposure, infection, and the need for quarantine.

Key takeaways:

  • Patients can be seen remotely, including from their homes, through telecommunications technology for the duration of the public health emergency, whether or not the patient lives in a rural area.
  • HHS is waiving HIPAA penalties for good faith use of technology, so providers and patients can use everyday services such as FaceTime, Skype, and Facebook messenger to communicate. The guidance stipulates that public-facing technologies such as Facebook Live, Twitch, and/or TikTok are not appropriate for telehealth.
  • Providers who offer telehealth services can waive or reduce cost-sharing, including co-insurance and deductibles.
  • Providers and patients who use telehealth are not required to have a previously established care relationship.
  • Some questions remain regarding whether providers in certain types of facilities, including Rural Health Clinics, Federally Qualified Health Centers, and Critical Access Hospitals, can remotely serve patients in their homes. We are closely tracking this issue and plan to provide clarity when it is available.

Other telemedicine services were available through Medicare before the new law and continue to be available. Those services include:

Virtual Check-Ins and Remote Evaluations
Medicare will reimburse providers for brief communications that take place with established patients through telephone, exchange of video or image information, secure text messaging, email, or patient portal. The purpose of virtual check-ins is for patients to briefly communicate with their doctors to determine if a longer visit is necessary. These check-ins are not limited to certain areas of the country. Medicare coinsurance and deductibles will generally apply to these services.

Medicare patients can participate in digital visits, including evaluation and management, with their established providers via an online patient portal. These visits must be patient-initiated, and communication may be over a seven-day period. They cannot be billed in Rural Health Clinics or Federally Qualified Health Centers, though this could change in pending legislation. Medicare coinsurance and deductibles will apply to these services.

Webinar on Thursday March 26 – Reserve your spot
Caravan Health is closely following the new guidance and policy changes as they are made public. We will hold an informative webinar on Thursday, March 26, at 9 AM PT/noon ET featuring Dr. Anna Loengard, Caravan Health Chief Medical Officer to discuss the changes and explain how this new telehealth option can help clinicians respond to this unprecedented health emergency. Register here.
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