Monthly Archives

October 2018

Issue in Focus: California Department Health Care Services Solicits Feedback on Major Telehealth Policy Changes

By | Center for Connected Health Policy

The California Department of Health Care Services (DHCS) released two draft proposals impacting telehealth policy in the state’s Medicaid program known as Medi-Cal.  The Department is soliciting feedback from interested stakeholders on both proposals.

California State Plan Amendment

The first proposal is a State Plan Amendment (SPA) intended for submission to the Centers for Medicare and Medicaid Services (CMS), that provides clarification as to when services provided outside of the “Four Walls” of a federally qualified health center (FQHC) or  rural health center (RHC) is eligible for the prospective payment system (PPS).  It is proposed that all such services be paid the PPS when rendered to homebound, migratory, seasonal workers and homeless patients, patients in the hospital, dental services rendered to established patients by a contracted dental provider, and telehealth services provided to its established patients when certain requirements are met.

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CALIFORNIA DEPARTMENT HEALTH CARE SERVICES SOLICITS FEEDBACK ON PROPOSED MAJOR TELEHEALTH POLICY CHANGES

By | Center for Connected Health Policy

Original Source: Center for Connected Health Policy

CALIFORNIA DEPARTMENT HEALTH CARE SERVICES SOLICITS FEEDBACK ON PROPOSED MAJOR TELEHEALTH POLICY CHANGES


The California Department of Health Care Services (DHCS) released two draft proposals impacting telehealth policy in the state’s Medicaid program known as Medi-Cal.  The Department is soliciting feedback from interested stakeholders on both proposals.
California State Plan Amendment

The first proposal is a State Plan Amendment (SPA) intended for submission to the Centers for Medicare and Medicaid Services (CMS), that provides clarification as to when services provided outside of the “Four Walls” of a federally qualified health center (FQHC) or  rural health center (RHC) is eligible for the prospective payment system (PPS).  It is proposed that all such services be paid the PPS when rendered to homebound, migratory, seasonal workers and homeless patients, patients in the hospital, dental services rendered to established patients by a contracted dental provider, and telehealth services provided to its established patients when certain requirements are met.

The proposed SPA lays out several requirements that apply to all of the exceptions listed above for services rendered outside of the Four Walls, and others that apply specifically to telehealth and store-and-forward services.  Among the general requirements, is the necessity to document services with the same specificity as would be required when services are provided within the Four Walls; the FQHC or RHC must provide written policies that describe all of the services that will be provided outside of the Four Walls, along with circumstances for which the services will be provided; and all HRSA policies and procedures for approved scope of projects apply.  Additionally, the SPA specifies that if the patient is assigned to a managed care plan that is responsible for the services being furnished by the FQHC or RHC, the FQHC or RHC must properly bill the managed care plan first for the services and meet the plan’s applicable credentialing requirements.

The telehealth specific requirements include the following:
  • “The telehealth communication system must allow the provider at the distant site to view the patient’s condition directly without the interposition of a third person’s judgement;
  • The originating site must have a current written agreement with the distant site to furnish the telehealth services. If the originating site compensates the distant site for the provision of telehealth services, the distant site cannot bill for the services outside the PPS rate.
  • The originating site must provide its established patient with specific information, such as the risks, benefits and consequences of telehealth, confidentiality protections, etc. … (See SPA text for complete details).
  • The originating site must document in the established patient’s health record the patient’s consent to telehealth services.
  • All health information transmitted during the delivery of telehealth services must be maintained by both the originating and distant sites.  Additionally, both originating and distant sites must document that the telehealth services were medically necessary with the same specificity required to obtain approved treatment authorization request (TAR); and
  • The telehealth services at the distant site must be provided by a licensed health care provider in California.”

Additionally, the SPA lays out specific rules for billing as well as for store-and-forward services provided for ophthalmology, dermatology, and dentistry for its established patients.  To learn more about the draft SPA proposal, see the full text.

DHCS has requested that any comments be submitted via e-mail to [email protected] and indicate SPA 18-0055 in the subject line by Nov. 2, 2018 no later than 5 pm. 

California DHCS Releases Draft Changes to Telehealth Medicaid Policy
Additionally, DHCS is also proposing to update and clarify its telehealth policy manuals within the Medi-Cal program for:
  • Fee-for-service
  • Managed Care
  • Indian Health Services
  • Family Plan, Access, Care and Treatment (Family PACT)
  • Teledentistry
  • FQHCs/RHCs

Among the most intriguing and exciting proposals in the draft is allowing the distant site/treating provider to decide when it is appropriate for telehealth to be used and whether it should be via live video or store-and-forward.  E-consult (provider to provider consultation), falling under the auspice of store-and-forward, would also be reimbursed through two CPT codes, making California along with Connecticut the only state Medicaid programs in the country reimbursing for that particular service.  Under Medi-Cal’s proposed draft policy, the services would still need to be a Medi-Cal reimbursable service and the CPT or HCPCS code definition should allow for technology to be used, but this proposed policy is far more advanced than most any other Medicaid policies seen in the country and follows what CCHP has suggested for many years: let the provider and patient decide whether it is appropriate to use telehealth in that particular moment.

Other intriguing proposals in the draft include expansion of the originating site to include the home and what appears to be other non-clinical locations as well as the aforementioned inclusion of the two e-consult codes.

Items that are missing or raise questions are no reimbursement for remote patient monitoring, confusion on licensing and location requirements of the telehealth provider and how does the proposed change in the manual intersect with the SPA?  For example, a “visit” for an FQHC and RHC is defined as occurring “face-to-face” in the proposed Medi-Cal policy manual for FQHC/RHCs, indicating that store-and-forward visits (which do not occur face-to-face) would potentially be excluded from coverage for FQHCs and RHCs.  However, the SPA indicates that FQHCs and RHCS may bill the PPS rate for ophthalmology, dermatology and dentistry store and forward services provided to established patients if certain requirements are met (as noted in previous SPA section).  It is currently unclear how to reconcile these seemingly conflicting policies between the documents.

Despite these points that need clarification, the proposed draft Medi-Cal telehealth policy represents a remarkable step forward.  Since the passage of and enactment of AB 415, the Telehealth Development Act, CCHP has long noted that DHCS had the ability in law to create a more expansive telehealth policy.  We are pleased to see such innovative and forward movement by the State.

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CMS Proposes Telehealth Expansion for Medicare Advantage Plans

By | Recent Telehealth News

Article Author: Eric Wicklund

Source: mHealth Intelligence

The Centers for Medicare & Medicaid Services is looking to expand telehealth access for members enrolled in Medicare Advantage plans.

As part of a 362-page proposal issued on October 26, the Centers for Medicare & Medicaid Services (CMS) is proposing to eliminate geographical restrictions on telehealth access in MA plans by 2020, enabling those in urban areas to use connected health technology. The proposal would also give members more locations to access care, including their own home.

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Updated & Redesigned Fall 2018 Edition of the 50 State Telehealth Laws and Reimbursement Policies Report

By | Center for Connected Health Policy

Original Source: Center for Connected Health Policy

An updated Fall 2018 edition of CCHP’s “State Telehealth Laws and Reimbursement Policies” Report is available today!  The Fall 2018 edition offers policymakers, health advocates and other interested health care professionals a freshly redesigned compendium of state telehealth laws, regulations and Medicaid policies.  The new report features the same detailed telehealth policy information (with references) found in previous reports, but in a fresh new format with policies grouped into three primary categories (Medicaid Reimbursement, Private Payer Laws, and Professional Regulation). This report was made possible through generous support from the Health Services & Resources Administration and the California Health Care Foundation.

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Physician Resistance to CMS Proposal for Virtual Check-Ins

By | Center for Connected Health Policy

Original Source: Center for Connected Health Policy

On July 12, 2018, the Centers for Medicare and Medicaid Services (CMS) released a proposal of revisions to the Physician Fee Schedule (PFS) for CY 2019. The proposal includes reimbursement for a virtual check-in service intended to “restore the doctor-patient relationship” by motivating physicians to communicate with patients outside of the office. The calls would help patients decide if they need to schedule an in-person appointment. CMS proposes to reimburse physicians $14 per five to ten-minute check-in call, and according to a Kaiser Health News article, physicians worry that patients would be required to pay 20% in cost-sharing.
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Federal Telehealth Initiatives Advance as More Telehealth Studies Reveal New Evidence

By | Center for Connected Health Policy

Original Source: Center for Connected Health Policy

Federal Spending Bill Includes Funding for Rural Veterans Telehealth Programs


A Federal appropriations bill for fiscal year 2019 was recently approved by the President. H.R. 6157appropriates funding until December 7, 2018 and includes $1,000,000 for the provision of mental and other health services to veterans and residents of rural areas. The grants are part of the Medicare Rural Hospital Flexibility Program and funds may be used to purchase and implement telehealth services, including pilots and demonstrations on the use of electronic health records for the coordination of rural veteran care.

States are eligible for the grants when they provide assurances that the state has developed, or is in the process of developing, a state rural health care plan that creates one or more rural health networks, promotes regionalization of rural health services, and improves access to hospital and other health services for rural residents. The plan must be developed in consultation with the hospital association of the state, rural hospitals, and the State Office of Rural Health. States must also designate rural nonprofit or public hospitals or facilities as critical access hospitals. Critical access hospitals must meet specific geographic and facility requirements.

The full text of the bill is available through the Congress website.

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Telemedicine Network Helps Virginia Hospitals Coordinate Care

By | Recent Telehealth News

Article Author: Eric Wicklund

Source: mHealth Intelligence

A new telemedicine platform is giving northern Virginia’s Culpeper Medical Center the opportunity to triage patients with cardiac or vascular issues before sending them, if necessary, on to the experts at UVA Medical Center.

Culpeper Medical Center, part of the Novant Health UVA health system, is using connected care technology to link its Emergency Department with specialists at UVA’s Heart & Vascular Center in Charlottesville, roughly an hour away. The specialists, using the video feed and the patient’s medical record, can consult with the patient and the patient’s family before deciding on a course of treatment, which could keep the patient at Culpeper or send him/her on to UVA for emergency or scheduled surgery.

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