AHA Tells MedPAC to Take its Time on Telehealth Coverage Recommendations

The American Hospital Association is asking the Medicare Payment Advisory Commission to hold off on long-term recommendations for telehealth expansion and coverage, saying more analysis is needed to chart a post-COVID-19 strategy.

The request, in a letter issued today to MedPAC Chairman Michael Chernew, PhD, comes as telehealth advocates and healthcare providers are asking federal officials to make permanent emergency measures enacted to address the coronavirus pandemic. Without a clear understanding of telehealth policy and regulation after the public health emergency, they say, health systems and hospitals will scale back or drop telehealth programs for fear of losing reimbursement.

The AHA recommends taking more time to study how telehealth has been implemented and what is needed in reimbursement to make telehealth sustainable. But the organization is also throwing support behind the abolishment of geographic site restrictions and expanded coverage for audio-only services.

The letter, penned by Ashley Thompson, senior vice president of public policy analysis and development, notes that the nation’s healthcare system has adopted connected health platforms and tools in record numbers to deal with the pandemic. But with the public health emergency expected to stay in place through at least the end of this year, there’s no rush to make recommendations on how the Centers for Medicare & Medicaid Services should cover telehealth after the PHE.

“The increased use of telehealth since the start of the PHE is producing high-quality outcomes for patients, closing longstanding workforce gaps and those that arose as a result of a sickened and exhausted provider corps, and protecting access for patients too vulnerable to risk infection,” Thompson says. “This shift in care delivery could outlast the PHE if the appropriate statutory and regulatory framework is established. To do so, stakeholders must have time to conduct in-depth analyses of how providers have used the telehealth flexibilities available during the pandemic and the quality of patient care provided through those flexibilities. Given that the pandemic is ongoing and that the Biden administration has suggested it will maintain the PHE declaration through the end of 2021, considerably more data points on the quality and cost effectiveness of telehealth services will be developed this year.”

That said, the AHA is making some recommendations of its own.

The agency is asking MedPAC to recommend eliminating 1834(m) geographic and originating site restrictions to Medicare reimbursement, saying telehealth coverage should extend to services delivered to the patient’s home and other locations, like federally-qualified health centers, rural health centers and skilled nursing facilities.

“Without this change, much of the progress that has been made over the past months to significantly increase patient access to care will disappear, since the status quo limits telehealth to rural areas of the country and requires patients to be at certain types of facilities to receive care,” Thompson says. “The PHE clearly demonstrated the need for access to telehealth in nonrural areas including in the safety of patients’ homes, and the importance of being able to reach patients who are completely removed from the health care system, such as homeless individuals in shelters.”

In addition, the AHA is recommending continued coverage and reimbursement for audio-only services.

“This flexibility has enabled our members to maintain access to care for numerous patients who do not have access to broadband or video conferencing technology,” Thompson says. “It has also protected the continuity of care when a video connection fails, a situation with which the nation is now intimately familiar due to the COVID-19 pandemic. In those situations, if a provider and patient are connected via audio/video technology, and their video connection fails, they can default to an audio-only visit and pick up right where they left off. Additionally, audio-only behavioral health services have become extremely popular with patients who are more comfortable without face-to-face visits.”

Finally, the AHA is calling for “adequate reimbursement” for telehealth services, including coverage for a wide range of upfront and ongoing costs. The organization isn’t going so far as to support payment parity, but it wants MedPAC to do more research on how much it costs for a provider to establish and maintain a telehealth program.

“To best support providers’ ability to deliver high-quality care and improved patient outcomes, there must be a thorough and complete accounting of the costs that go into providing virtual visits and how such expenses relate to the need to maintain capacity for in-person services,” Thompson says. “There are, in fact, significantly more actions that hospital staff and providers must take to execute a virtual visit than they do for an in-person visit.”

“Without funding to cover these numerous added steps, it will be difficult-to-impossible for hospitals and health systems to provide telehealth at the level at which patients are demanding,” she adds. “The goal of expanding telehealth should be integrated care across modalities to achieve the most appropriate and efficient care for patients.”

To that end, the AHA suggests that CMS create a “practice expense value” for telehealth, which would take into account the many factors that go into a virtual visit and “generate a payment for telehealth that reflects the inputs for delivering this service, obviating the need for artificial reductions to telehealth payment simply because it is a different modality of care.”