As we approach four months of the COVID-19 pandemic’s disruption of the U.S. healthcare system, so much has changed and much remains unknown. Here are a few items that we know for sure right now:
1. CMS is on-board with telehealth long term. Administrator Seema Verma recently told the Wall Street Journal, “The genie’s out of the bottle… It’s fair to say that the advent of telehealth has been just completely accelerated, that it’s taken this crisis to push us to a new frontier, but there’s absolutely no going back.”
2. NCQA, which rates health insurance plans on a scale of 0−5, will not release 2020–2021 Health Plan Ratings. (Accredited commercial and Medicaid plans will still need to submit their HEDIS and CAHPS measures.)The organization has also updated telehealth guidance in 40 HEDIS measures for 2020 and 2021 to align with CMS and support the increase in telemedicine usage since the start of the COVID-19 pandemic. NCQA is updating its guidelines on how Patient-Centered Medical Homes can use telehealth for mental health care and meet NCQA criteria.
3. Thanks to virtual visits, many physicians have been able to keep certain patient appointments during the pandemic. But what about those that could not happen virtually? The CDC notes that there has been an under-utilization of important medical services for non-COVID-19-patients with urgent health needs during the last few months—and recommends that health systems balance the risks of the pandemic with the risks of further treatment delays. The organization also acknowledges that the pandemic is an ever-changing situation and the right course of action for your practice can vary greatly by day and by location.
4. Since the start of the COVID-19 pandemic, Medicare plan member interest in telehealth has increased from 5% to 20%. And more than 40% of Medicare Advantage members are looking for health plan information online.
5. The American Medical Association’s Perspectives from the AMA podcast has released an episode on best practices for reopening physician offices during COVID-19.
6. Our friends at Orderly Health built this COVID-19 Access Guide to help the public search for local resources. (Be sure to scroll down to check out the Smile section for some much-needed positivity.)
Start Booking Virtual Appointments Today with ReferWell
We have launched telehealth capabilities to help you improve patient access and refer to your preferred, in-network specialists. You will also find local COVID testing sites in ReferWell to help with patient appointment scheduling.
Providers may now use ReferWell’s telehealth service free of charge for the duration of the pandemic. Or, connect through your native service.
Frequently Asked Questions
Physicians can choose to use telehealth while stay-at home orders are in effect.
- Telehealth is the use of electronic communication to provide and support healthcare to patients. For mental health therapists, this is inclusive of written, phone, and video-based communications.
- Telehealth tools that aren’t HIPAA compliant are allowed to be used during the state of emergency.
- Given the sensitivities around personal health data, we recommend all digital communications be HIPAA-Compliant.
- In order to mitigate exposure of patients who are sick or at-risk due to other conditions, as well as protect the healthcare workers and community, practices are strongly encouraged to use telehealth whenever possible and to consider establishing protocols and procedures for use by practice staff and clinicians.
- Doctors should use telehealth when deemed appropriate for both new and existing patients.
- There are two broad categories of services that are being authorized remotely: Evaluation and Management, and Assessment and Management.
- Telehealth tools that aren’t HIPPA compliant are allowed to be used during the state of emergency.
- Please review the NYS DOH FAQ on telehealth.
The HHS has announced they will allow the use of popular video conferencing applications, including Apple FaceTime, Facebook Messenger video chat, Google Hangouts video, or Skype, for medical services during this state of emergency. We highly recommend the use of HIPAA compliant application to protect your patient’s privacy. Based on our research, that includes the following applications:
A BAA is not required during this state of emergency, but is strongly encouraged. As of March 23, 2020, the HHS has specifically outlined that they will not be enforcing standard HIPAA requirements as long as good faith measures are taken to ensure patient privacy. Good faith measures include notifying patients that these third-party applications potentially introduce privacy risks. Providers should also enable available encryptions and privacy modes when using telehealth applications.
We recommend a transition plan to a more HIPAA-secure environment. We have identified some example vendors above.
Yes, they are compliant, but some insurers may not reimburse telehealth that is not audiovisual (be sure to check with each individual insurer’s policy as these currently differ)
Medicare will reimburse for telephone (audio-only) consultations with practitioners (medical and non-medical) using for evaluation and management (E&M) services by medical professionals. The CPT codes are 98966-98968 and 99441-99443 respectively.
- Ensure you have a strong internet connection.
- Make sure you are in a private and secure space.
- Make sure you have proper lighting and a solid dark background (without a lot of distracting motions).
- Keep background noise to a minimum – this is crucial to maintaining a professional atmosphere.
The CARES ACT increases hospital payments for treating patients admitted with COVID-19 by 20% during the COVID-19 emergency period. Qualified hospital facilities can receive up to a six-month advanced lump sum or periodic Medicare payments based on net reimbursement represented by unbilled discharges or unpaid bills during the COVID-19 emergency. Many hospital types could elect to receive up to 100% of the prior period payments, while Critical Access Hospitals could receive up to 125%. Qualifying hospitals would not be required to pay down resultant loans for four months, and would have at least twelve months to complete repayment without interest.
The CMS fact sheet on accelerated or advanced payments can be found here.
- Evaluation and management (E&M) services by medical professionals
- Assessment and patient management by all other Medicaid professionals, whether through fee schedule or by rate
- Offsite E&M by clinics, ambulatory surgery centers, or other programs
- Offsite E&M by Federally Qualified Health Centers (FQHCs)
- Any other appropriate service.
New York State has enacted the Emergency or Disaster Treatment Protection Act, which grants health care facilities, professionals, and volunteer organizations immunity from criminal or civil liability for actions that occur in the course of providing health care services during the COVID-19 emergency, unless due to intentional misconduct or gross negligence. The waiver is not strictly limited to COVID-19 treatment.
- “Facilities” include Article 28, 31, and 16 licensed programs or any other facility authorized by a COVID-19 emergency rule.
- “Professionals” include physicians, physician extenders, pharmacists, nurses, midwives, psychologists, social workers, other mental health practitioners, respiratory therapists, clinical laboratory workers, nursing attendants or certified nursing aides, emergency medical technicians, home care services workers, administrators and executives, and any other person authorized by a COVID-19 emergency rule.
Insurers will not be permitted on retrospective review to deny claims for emergency department and inpatient services related to COVID-19 treatment during the emergency.