Continued Telehealth Developments as 2018 Comes to a Close

Original Source: Center for Connected Health Policy

Medicare Report Reveals Medicare Telehealth Utilization, Barriers & Opportunities
In response to a requirement in the 21st Century Cures Act to issue a report on telehealth use, barriers and opportunities in Medicare, CMS released an informational report on November 15th addressing telehealth utilization, activities by the Center for Medicare and Medicaid Innovation, and opportunities and barriers to the use of telehealth within Medicare.  Utilizing data from Medicare fee-for-service between 2014 and 2016, the report revealed that although overall use of telehealth has increased, the rate of adoption is still limited.  Mental health and therapy sessions were the most common service types, with beneficiaries with a mental health diagnosis among the highest utilizers of telehealth delivered services.  Services targeting chronic diseases and behavior modification (such as smoking cessation) were also among the more popular telehealth delivered services.  The analysis determined that there are 19 additional high volume services for outpatient and inpatient visits and therapy that are either similar to those that are already on Medicare’s list or that are typically provided in settings that do not meet Medicare’s originating site requirements that would be suitable for telehealth delivery.  CMS concludes that restrictions on eligible telehealth originating sites is the greatest barrier preventing the expansion for telehealth within Medicare.

For more details and further statistics on telehealth in Medicare,
see the full report.

CMS Webinar & New Stroke Modifier
After CMS released their final rule on the CY 2019 Physicians Fee Schedule (PFS) in early November, which contained several significant telehealth policy changes, CMS held a webinar presentation on November 19th where they addressed the telehealth changes and answered questions from attendees.  The webinar slides, recording and transcript are currently available to the public.  CMS’ newly adopted policies expands Medicare telehealth services, and communicates a new interpretation by CMS of the applicability of their statutory requirements for reimbursement of remote communication technology as separate from telehealth, and adds new services based on this interpretation.  Specifically, it allows for reimbursement of virtual check-ins, remote evaluation of pre-recorded patient information and interprofessional internet consultations.  CMS also adds new codes to the Medicare telehealth list, chronic care management and remote patient monitoring and expands telehealth reimbursement for end stage renal disease and acute stroke based on requirements in the Bipartisan Budget Act of 2018.


For more information, read the full text, and see CCHP’s factsheet and infographic on the proposal.  Also, see CCHP’s webinar sponsored by the Consortium of Telehealth Resource Centers on the CY 2019 PFS changes as well as a proposed rule on Medicare Advantage and an update on state telehealth policy.


At the end of November CMS also finalized through a separate announcement, the new modifier to be used to identify the stroke services that would qualify for the specific exceptions made in the PFS to the telehealth originating site and geographic requirements for acute stroke treatment.  The modifier G0 (G zero) will be required to be appended on all such claims.

Telehealth Recognized as Avenue to Increase Healthcare Competition in HHS Report

In early December the Department of Health and Human Services (HHS) in collaboration with the Departments of the Treasury and Labor, the Federal Trade Commission, and several offices within the White House released a report that describes state and federal policies’ impact on choice and competition in health care markets and identifies areas the government could develop a better functioning system.  The report recognizes telehealth as an avenue to increase competition and choice in health care, stating that “telehealth often increases the virtual supply of providers and extends their reach to new locations, promoting beneficial competition. By doing so, telehealth can enhance price and non-price competition, reduce transportation expenditures, and improve access to quality care.”  However, the report acknowledges several barriers to the use of telehealth including state licensing restrictions, and public and private reimbursement.  Recommendations include states adopting licensure compacts or other models of licensure portability, modifications to reimbursement policies, and allowing providers and payers to mutually determine when it is safe and appropriate to utilize telehealth services.
For further details see the full report.

Draft Project to Establish Guidance on Remote Patient Monitoring Privacy and Security
The National Cybersecurity Center of Excellence (NCCoE) at the National Institute of Standards and Technology (NIST) has released a draft paper outlining a project focusing on solutions for improving privacy and security in telehealth and remote patient monitoring (RPM). NCCoE is seeking feedback on the project which will result in a public NIST Cybersecurity Practice Guide.

The proposed project will demonstrate a solution to concerns with devices commonly used in home RPM, such as home networks and patient-owned devices which may not meet the same security standards of telecommunication technologies used by providers in a clinical setting. The paper outlines the high-level architecture of RPM, addresses the components involved in the delivery of various services, and outlines desired security features including:

  • IDENTIFY (ID) – These activities are foundational to developing an organizational understanding to manage risk.
  • PROTECT (PR) – These activities support the ability to develop and implement appropriate safeguards based on risk.
  • DETECT (DE) – enables the timely discovery of a cybersecurity event
  • RESPOND (RS) – the ability to develop and implement activities designed to contain the impact of a detected cybersecurity event
  • RECOVER (RC) – the ability to develop and implement activities that support the timely recovery of normal operations after a cybersecurity incident

Based on these security features, NCCoE plans to evaluate specific functions common to RPM delivered services and create a guidance demonstrating the application of best practices and standards such as IEC TR 80001-2-2, HIPPA, and ISO/IEC 27001.

Comments may be submitted to by December 21st, 2018.

The full publication, listing the project in further detail, is available on the NCCoE website.


AHRQ Grant to Study Antibiotic Prescriptions for Telehealth 


The Department of Health and Human Services’ Agency for Healthcare Research and Quality (AHRQ) has awarded a five year grant to Teladoc Health, the University of Southern California (USC) Schaeffer Center for Health Policy & Economics and Northwestern University, to collaborate on a study to assess antibiotic prescribing practices in telehealth. Their press release on the study states that the “study is expected to set a new precedent in medical literature by adding specific standards for telehealth and virtual care.”  The study is expected to include the largest ever randomized controlled trial in telehealth, and specifically examine prescribing behavior.  The results of the study could have a lasting impact on how telehealth prescribing policy develops, given the concern related to the over-prescribing of antibiotics and the danger of the resulting “super bugs” that are antibiotic resistant.  However, the lengthy five year study period will also mean that many telehealth prescribing policies will have already been established by the time the findings become public.

For more information, see the press release.

Research Shows Trends in Telemedicine Adoption
New research published in the Journal of the American Medical Association (JAMA) examines telemedicine use trends within a large privately insured population residing in rural and urban areas across the United States between 2005 and 2017. The analysis concludes that the use of telemedicine visits within the population of over 200,000 increased from 0.02 per 1,000 members to 6.57. However, data showed a negative correlation between the growth in uptake and states with stricter parity laws mandating reimbursement for telemedicine-delivered services.

The research also reflects a recent USDA survey which showed that rural populations are less likely, compared to urban populations, to use telehealth or other technology-based health care services. Although telemedicine could address health care access needs in rural communities, both studies show that it is used more frequently in primary care settings by urban populations. The USDA survey suggested that the slow uptake among rural communities may be due to a combination of lower adoption among rural providers and less access to broadband services.
The research letter is available with a subscription through the JAMA Network.


CCHP Executive Director Talks 5G Connections and Telehealth Policies in The Hill Video Series


Check out this new short video documentary, produced by The Hill, which explores how 5G is revolutionizing the field of health care and propelling telemedicine’s growth.  The video, which is a part of the “Boundlesss” series, includes an interview with CCHP’s executive director, Mei Kwong, who points out that reducing the lingering state and federal policy barriers to the use of telehealth and allowing the provider and patient to decide when and how it should be used will spur even further advancements.
Boundless” is a multi-part Hill.TV documentary series focused on technological advancements. 
For more information visit the official The Hill website .


California DHCS Telehealth Webinar

The California Department of Health Care Services (DHCS) is hosting a webinar on Monday, December 17, 2018, 2-3:00 PM PST on the department’s telehealth policy. This webinar will provide updates regarding DHCS’ telehealth policy revisions, including the changes to the various Medi-Cal Provider Manual sections and All Plan Letter. Through this webinar, DHCS will share some of the commonly asked questions and comments received from stakeholders regarding Medi-Cal’s proposal to increase flexibility for providers on the use of telehealth, including e-consults, as well as DHCS’ response to those questions and comments.
For more information or to register for this webinar
view the DHCS registration site.

TEXAS: Board of Nursing – Telemedicine Medical Service Prescriptions

Clarifies that the validity of a prescription for the Nursing Board is determined by the same standard that would apply in an in-person setting.  Also specifies that the treatment of chronic pain with scheduled drugs through the use of telemedicine medical services is prohibited unless otherwise allowed under federal and state law.  Treatment of acute pain is allowed with scheduled drugs through telemedicine medical services unless prohibited by law. VIEW REGULATION INFO  (11/16/18:  Rule finalized, Now Effective)

TENNESSEE:  Board of Dentistry – Teledentistry

The proposed rule establishes practice standards for teledentistry, including requirements around the modality used in teledentistry, record keeping, supervision and informed consent requirements. VIEW REGULATION INFO (11/5/18: Proposed, Hearing Date: 1/10/19)

OREGON: Division of Medical Assistance Programs – Medicaid Teledentistry

Establishes a new rule to provide guidance to Medicaid dental providers on teledentistry. Includes definitions for ‘teledentistry’ and telehealth modalities. Establishes patient’s rights and general billing requirements.  VIEW REGULATION INFO (11/2/18: Proposed, Comment Deadline: 12/20/18)

OREGON: Division of Behavioral Health Services – Intensive Treatment Services for Children

Adds a new definition for ‘face-to-face’ which accounts for services delivered through telehealth modalities. VIEW REGULATION INFO (11/20/18: Proposed, Comment Deadline: 12/20/18)

WASHINGTON D.C.: Department of Insurance, Securities and Banking – Network Adequacy

Establishes standards for the creation and maintenance of networks by health carriers and ensures adequacy, accessibility, transparency and quality of health care services. Requires health carriers to describe the extent to which they support the use of telemedicine or other technology to enhance network access within their Access Plan. VIEW REGULATION INFO (11/23/18: Proposed, Comment Deadline: 12/23/18)