All Posts By

Ray Dizon

North Dakota Advances Bill that Allows for Valid Relationship Over Store-and-Forward Telemedicine

By | National Telehealth Policy Resource Center Blog

In North Dakota’s SB 2094, which was introduced in early January and amended in the Senate Human Services Committee later that month, has been gaining some attention in telehealth circles due to some of its more unique characteristics; largely because it allows a valid relationship between a licensee and a patient to be established over telemedicine.  Alone this is not unique, as it is relatively common for states to allow a licensee-patient relationship to be established via live video telemedicine (CCHP has identified at least 28 states with this explicit allowance).  However, the legislation specifies that the examination can take place either via video conferencing or “store-and-forward technology for appropriate diagnostic testing and use of peripherals.”  It goes on to specify that in certain types of telemedicine utilizing asynchronous store-and-forward technology or electronic monitoring, such as teleradiology or intensive care unit monitoring, it is not necessary to conduct an independent exam of the patient.  This allowance for store-and-forward to be used in establishing a valid relationship is rare.
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CMS Begins Virtual Communication Reimbursement as States Take Different Approaches to Telehealth Policy

By | National Telehealth Policy Resource Center Blog
CMS Releases Virtual Communication FAQs & MLN Matters Guidance for RHCs and FQHCs
Beginning January 2019, the Centers for Medicare and Medicaid Services (CMS) began reimbursing for certain kinds of services furnished remotely using communications technology that are not considered “Medicare telehealth services.” Because they are not defined specifically as telehealth, the limitations and restrictions generally applicable to telehealth in Medicare do not apply.  These services include “virtual communication services” including communication technology-based services (HCPCS code G2012) and remote evaluation services (HCPCS code G2010).  However, due to the unique rules that apply to federally qualified health centers (FQHCs) and rural health clinics (RHCs), CMS has assigned a new code (G0071) specifically for these safety-net clinics to utilize for virtual communication services as they are not eligible to bill G2010 or G2012.  As a result of this policy change, CMS has released an FAQ document on the topic to help clarify any confusion around the use of the new code for FQHCs and RHCs.  View the FAQs for the full scope of the questions and concerns answered through the document.

Additionally, a Medicare Learning Network (MLN) Matters document was also released with instructions for FQHCs and RHCs billing Medicare Administrative Contractors (MACs) for communication technology-based services.  The document stipulates that the payment rate for G0071 is set at the average of the Physician Fee Schedule (PFS) non-facility payment rate for communication technology-based services and remote evaluation services, and that the face-to-face requirement that normally applies to RHCs and FQHCs is waived for these services.  For more information on the requirements, see the full MLN Mattersdocument.

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Federal Bill Aims to Expand Medicare Reimbursement for Mental Health Telehealth Services

By | National Telehealth Policy Resource Center Blog

In late December 2018 US Senator Kamala Harris’ office announced through a press release that she would be introducing two bills aimed at increasing access to mental health services, one of which would expand Medicare reimbursement for mental health services provided through telemedicine.  The bill, introduced in the 115th Congress (2017-2018 Legislative Session) as S. 3797 and is titled the “Mental Health Telemedicine Expansion Act”, would define mental health telehealth services as those covered by CPT codes 90834 and 90837, both of which describe individual psychotherapy. These services are already covered by Medicare when delivered via live video, but are currently subject to Medicare’s originating site and geographic restrictions.
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California DHCS Releases Comment Responses to Proposed Telehealth Policy

By | National Telehealth Policy Resource Center Blog

In late 2018, the California Department of Health Care Services (DHCS), which administers California’s Medicaid program (Medi-Cal), released proposed updates to their telehealth policy manuals, including those for fee-for-service, managed care, Indian Health Services, Family Plan, Access, Care and Treatment (Family PACT), dentistry and federally qualified health centers/rural health clinics (FQHC/RHCs).  Proposed policy changes included 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 under the new policy.  As part of their drafting process, DHCS solicited feedback from telehealth stakeholders on their proposed policy.
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CCHP Publishes Analysis of Occupational and Physical Therapy Policy

By | National Telehealth Policy Resource Center Blog

Last year, CCHP conducted a 50-state scan of occupational therapy and physical therapy policies that was published in the fall 2018 edition of the International Journal of Telerehabilitation. The survey results show the current level of adoption of both laws and regulations that allow physical and occupational therapists to use telehealth to engage in patient care services as of August 2018. CCHP found that twenty-seven states had enacted at least one policy that allows patient-to-provider or provider-to-provider services in occupational therapy, while twenty-eight states had done the same for physical therapy. The specific requirements laid out through these policies varied by state, but none appeared to add additional burdens to providers.

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2019 KICKS OFF WITH EXPANDED REIMBURSEMENT ANTICIPATED IN MEDICARE ACOs & CA MEDICAID (Medi-Cal)

By | National Telehealth Policy Resource Center Blog
ACO Telehealth Expansion in Medicare Shared Savings Program

As required by the Bipartisan Budget Act, CMS has finalized their rule to broaden telehealth reimbursement for Medicare Accountable Care Organizations (ACOs) in the Shared Savings Program under the BASIC track (under a two sided model) and ENHANCED track when the ACO elects prospective assignment.  The finalized regulation allows eligible physicians and practitioners in the applicable ACOs to be reimbursed regardless of the geographic location of the patient and allows the home to be the originating site.  If the home was the originating site, there would be no facility fee allowed.  Other locations, besides the patient’s place of residence, would not qualify for reimbursement under the new rule, such as a school.  Other Medicare telehealth requirements would still apply, such as provider type and service code limitations.  Additionally, CMS also clarifies in the rule that in the case where the beneficiary’s home is the originating site, Medicare will not pay for telehealth services that are inappropriate to be furnished in the home even if the services are on the approved list of telehealth services, such as inpatient hospital visits.  The change would not be applicable until plan year 2020.

To learn more, read the full text of the rule.

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