Hospice Care Providers Ask CMS to Make Telehealth Coverage Permanent

Hospice providers are asking that Medicare continue to cover telehealth services beyond the current coronavirus pandemic.

In a letter sent last week to the Centers for Medicare & Medicaid Services, National Association for Home Care & Hospice (NAHC) President William A. Dombi asked that guidelines relaxed during the current crisis to expand telehealth coverage be made permanent.

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“Roughly 98 percent of hospice care is delivered at the Routine Home Care (RHC) level of care, in a patient’s place of residence,” Dombi said in the letter to CMS Administrator Seema Verma. “In such cases there is limited control over the environment and over potential exposure to illness. Further, in cases where patients reside in nursing facilities, direct access to hospice patients to conduct in-person visits has been dramatically curtailed. For these reasons the flexibilities granted by CMS relative to use of telecommunications technology – where feasible and appropriate, and in keeping with the hospice plan of care – have allowed for the continuation of vital hospice services.”

Noting there’s no timeline on when the emergency measures will end, Dombi said “it is an appropriate time to begin discussions around steps that can be taken by CMS to establish permanent Medicare policies related to the ongoing use of telecommunications technology in hospice care. Further, it may be time to set in motion actions that will allow for proper monitoring of utilization of technology-based visits and for assessment of their impact on quality of care outside of the current public health emergency.”

As part of the CARES Act, signed into law in March, CMS expanded coverage for some connected health services delivered to hospice patients, thereby enabling hospice care providers to use telemedicine and mHealth technology to connect with patients and their families at a time when in-person care was largely curtailed.

In his letter, Dombi asks CMS to:

1. “Clarify that hospice providers are permitted to use telecommunications technology — as appropriate and feasible, and in compliance with applicable HIPAA requirements — to perform service visits as determined by the IDT and as outlined and specified on the plan of care beyond the current public health emergency;”
2. “Fast-track development of modifiers or revenue codes that reflect various types of telecommunications-based visits for use in reporting on hospice claims;”
3. “Clarify that hospice providers may include telecommunications-based visits as part of visit reporting under Section O of the HIS Discharge record; and”
4. “Develop regulations that permanently allow the hospice F2F recertification to be completed using telecommunications technology where feasible and appropriate.”

With telehealth adoption at record levels, advocates across the board are beginning to plan for the future beyond the pandemic, and they’re arguing that many of the emergency rules enacted by federal and state regulators be made permanent to keep that momentum going.

They’re also urging care providers to plan for when these emergency rules end, and HIPAA (Health Insurance Portability and Accountability Act) guidelines and other rules are restored.

“Hospices would need to ensure that they’re using the right platforms that do provide appropriate protection,” Theresa Forster, vice president for hospice policy and programs for the NAHC, recently told Hospice News. “That’s going to be an important step moving forward. It’s going to be very important for them to understand that while they may be using Zoom or Skype now, in the long term there is definitely going to be a standard they will need to meet.”