The Medicare Payment Advisory Commission (MedPAC) is the latest group to evaluate telehealth reimbursement expansions post COVID-19 pandemic.
In a meeting held virtually in the start of September 2020, MedPAC analysts Ariel Winter and Ledia Tabor shared some policy ideas for keeping telehealth coverage and reimbursement expansions post the pandemic now that providers across the country are robustly leveraging telephonic and virtual services to prevent the spread of the virus.
Their idea was to ask clinicians to participate in Advanced Alternative Payment Models (A-APMs) to continuing providing telehealth services to patients outside of rural areas and to patients in their homes.
Under this new policy option, clinicians in A-APMs that contain financial risk for total Medicare spending and quality of care would be able to have the benefit of most telehealth expansions, including higher payment rates for telehealth services and the delivery of telehealth to patients in non-rural areas and in-patient homes.
Reimbursement for Telehealth would also encourage the participation of providers in the alternative payment models, which is the eventual goal of the Quality Payment Program.
Telehealth Flexibility Post Pandemic
Providers participating in the general Medicare fee-for-service system would not get the same telehealth flexibility in this post-pandemic world though.
Winter said, “Giving the same flexibility to clinicians who do not participate in an A-APM poses a risk of overuse,” according to an official transcript of the meeting.
Some types of techniques or steps should be added post pandemic to allow telehealth reimbursement expansion to continue throughout Medicare, considering large healthcare fraud cases involving fraudulent billing of services ordered via telehealth.
Providers in A-APMs do not face the same incentives to overuse telehealth services. Providers in A-APMs would strive to control telehealth use like they control utilization, the analysts added.
Mental health services could be a good candidate for telehealth reimbursement expansions after the pandemic, they suggested, considering historical access issues.
According to Winter, “The issue is that services delivered via telehealth probably do not have the same practice costs as services provided in a physical office. Therefore, continuing to set rates for telehealth services that are the same as rates for in-office services could distort prices and could lead clinicians to favor telehealth over comparable in-person services.”
CMS and policymakers also should consider not covering audio-only services allowed during the public health emergency.
“Because clinicians are unable to visually examine patients during audio-only visits, it is possible that they will lead to new services instead of substituting for existing ones and, therefore, could increase program spending. Therefore, policymakers might want to consider not covering audio-only services after the PHE, even when provided by clinicians who are in A-APMs,” Winter stated.
Providers have been calling on CMS to continue telehealth reimbursement parity beyond the public health emergency to support virtual care efforts.
Administrator Verma later said in a Health Affairs blog post that the agency is assessing telehealth reimbursement rates post-pandemic. But officials have similar concerns as MedPAC – telehealth visits require different resources than an in-person visit even though new processes and workflows do have associated costs.
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