Following the lead of the federal government, many state legislatures are evaluating bills to increase the services that telemedicine providers can provide and allowing for reimbursement. These changes follow the development and adoption of several remote patient monitoring tools, as well as clarifying rules and procedures for reimbursement for telemedicine services.
CMS published their Calendar Year 2019 Physician Reimbursement Fee Schedule with several changes that impacted telemedicine service reimbursement. In the past, patients had to be physically in a rural or remote clinic where telemedicine services were provided. This continued to impact the patients who were geographically isolated or who had significant challenges with transportation, such as those suffering from End Stage Renal Disease or stroke. New communication technologies allow telemedicine evaluation and treatment from home or work, and these consultations will now be reimbursed.
In addition, two types of services will be reimbursed that were previously managed by support staff or performed as a professional courtesy. A virtual check in by a provider over a communication device, and inter-professional internet consultation will both now be reimbursable services.
Regulatory and Licensing Oversight
There are over 90 bills before various state legislatures that are seeing to clarify regulatory, oversight, licensing, and other administrative issues related to remote health care. Other bills are trying to clarify changes to reimbursement practices, following the changes the federal government adopted for Medicare and Medicaid. Some of these changes include:
- private payers cannot impose restrictions or qualifications for telemedicine providers that are more stringent than they impose on in-person health care providers.
- co-payments and deductibles cannot be higher for telemedicine services than for in-person health care.
- telemedicine systems can use providers licensed under interstate compacts.
New Patient Care Technologies
One of the most exciting changes in existing reimbursement practices is the adoption of new remote monitoring technologies. Both remote patient monitoring (RPM) and asynchronous or store and forward monitoring technologies are an exciting development in allowing patients to continue to work and be active, while health care maintains a careful watch over critical parameters. Medicare has added four ICD-10 codes related to reimbursement for various remote monitoring episodes of care. Many states are following the federal government example and passing legislation that also allows their state-run private and public insurance companies to provide these new services.
Some of the new connected or smart medical devices are implantable monitors such as cardiac monitors with Bluetooth capability, allowing the data to sync to an app on a smartphone. Continuous glucose monitors can provide much more accurate data for both patients, caregivers, and health care providers, and allow patients with diabetes to fine-tune their care. For patients with congestive heart failure, a store and forward device that monitors weights for a week at a time can prevent unneeded ER visits and hospitalizations by allowing changes in therapy rapidly and before a crisis.
Telemedicine Treatment of Substance Use Disorders
One challenging area of telemedicine regulatory oversight continues to be the remote care of the person suffering from Substance Use Disorder. Current pharmacological treatments for opioid use disorder are very effective, but are themselves controlled substances and at risk for diversion. The DEA regulates, along with state boards of pharmacy, controlled substance prescribing, and this oversight complicates interstate compacts for providers.
Trying to balance competing concerns of treatment access for those seeking help with addiction, and the risk of diversion for an opioid prescribed via telemedicine, CMS has written new guidelines for telemedicine treatment of Substance Use Disorder. These new guidelines include controlled substance prescribing, and the guidelines are now in the public comment stage. Telemedicine providers specializing in addiction medicine hope this new law will improve ease of access to care for those who are seeking help with their addiction.
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