How many articles do you see these days that mention telehealth? It's being discussed in white papers, articles, case studies, interviews, policy conversations, and more. I personally skim though at least five a week, carefully read at least two of them, and then typically file several others in my ‘read later’ file. I simply don’t have time to read it all, no matter my resolve to stay abreast of all things payment policy. The telehealth topics cover the spectrum of healthcare: inpatient, emergency medicine, psychiatry, obstetrics (especially for high-risk pregnancies), and mental and behavioral health. Whatever the specialty, it can now be done through a virtual visit.
Telehealth seems to be the only thing some people can talk about, but for good reason.
So, what is all the fuss about? Besides the COVID-19 pandemic and the thousand-fold increase in telehealth services across the healthcare ecosystem, of course. You read that right! There was a 1,000% increase in the use of telehealth in March 2020, a 4,000% increase in April 2020, and a 13,000% increase in telehealth visits for Medicare patients in a period of a month and a half. That’s a lot of virtual visits!
CMS telehealth changes due to the COVID-19 pandemic
To be fair, Medicare wasn't a big promotor of telehealth until it became the only option for clinicians to see their elderly patients and keep them safe from a potentially deadly infection. In fact, the Medicare claims processing manual is very specific about which conditions are eligible for telehealth outside of a public health emergency. Previously, if your patient didn’t reside in a health professional shortage area or a non-metropolitan statistical area, you were simply out of luck. On top of that, the home, as an originating site for telehealth services, was not permitted.
Like everything else, Medicare telehealth rules changed with the public health emergency of COVID-19 and as a result, most people agree that we will likely never go back to a world where healthcare services are administered via in-person visits only. There are currently at least three policies being debated in Congress to define what telehealth will look like once the public health emergency officially ends, likely sometime in 2021.
The Creating Opportunities Now for Necessary and Effective Care Technologies (CONNECT) for Health Act of 2021 has been reintroduced in Congress with widespread industry support and bipartisan support in both the House and Senate - an unusual feat in the current political environment! Also on the docket are the Telehealth Modernization Act of 2021 (HR 1332/S 368) and the Protecting Access to Post-COVID-19 Telehealth Act of 2021 (HR 366). It seems that we will see legislation in 2021 that includes protecting access to telehealth services for Medicare beneficiaries. The debate centers around program integrity and preventing fraud and abuse, not around whether telehealth is here to stay.
Incorporating telehealth into your organization’s workflow
Clearly, telehealth is something healthcare companies should be thinking about - the question is, what are you going to do about it? What’s your strategy to incorporate telehealth in your organization’s workflow and processes? While that depends on your organization type and where you sit in that organization, the one universal item is that policies and situations will change in the coming months, creating chaos for healthcare companies trying to organize around the changing guidance. It will be challenging to track all the changes Congress and the Department of Health and Human Services are making this year.
Specifically, Payers will need to formulate payment polices and configure claims systems to ensure automated processing of telehealth related claims. Providers will need to develop guidelines and targeted programs for telehealth in their organizations. Especially important to anyone involved in value-based care arrangements will be leveraging telehealth for new payment programs such as Remote Patient Monitoring, Chronic Care Management and Primary Care First. These programs are a great fit for the expanded use of technology. Chronic care management can be provided 100% remotely and has proven value reducing the overall cost of care. Remote Patient Monitoring allows clinicians to monitor the health of fragile patients on a daily basis, giving both the patient and the providers peace of mind.
Using proper reference data can help streamline your processes
As you formulate your plans and deploy new strategies for adapting to the new normal, you will need reference data in the form of value sets that you can use to segment patient populations for targeted programs around your value-based care programs. This same reference data can be used to create benefit policies, configure claims systems, and develop polices for use of telehealth at provider organizations.
Telehealth and claims processing
I have talked with clients that are paying any and all telehealth claims that come through their systems, then going back and analyzing what they may have paid inaccurately to determine what their claims configurations should be after the public health emergency. They may or may not be going back to reclaim money paid out that should not have been. Wouldn’t it be nice to have reference data that allows you to configure your claims payment system to pay for only those services that are appropriate to be provided over telehealth and provide value to your members?
For example, many members are experiencing mental health difficulties and finding great value in accessing providers via telehealth visits. Reference data for this use case would include: diagnosis codes that define mental health conditions, the procedure codes for various types of counseling and services for mental health, and the modifiers that would need to be on a claim in order for it to pay appropriately for mental health services delivered via telehealth. The Health Language telehealth reference data set will include all the codes approved by CMS for payment broken out by specialties like mental health, remote patient monitoring, alcohol and substance abuse, evaluation and management, and many more. Also included in the data set will be value sets that define the diagnosis relevant to the particular specialties.
Segmenting and customizing value sets
We realize that every organization will view telehealth differently, so we have the capability to segment and customize the value sets in ways that align with your organization’s strategic decisions. Keeping in mind that Social Determinants of Health will be an important factor in knowing who to target for specialized program using telehealth, we are also offering value sets that can help you to identify those patients that could benefit most from these programs - but that’s a topic for another day. Stay tuned!
For more information on Wolters Kluwer Health Language telehealth offerings, reach out to us today! We would love to help support you wherever you are in adopting telehealth into your own organization.