The wind may be even stronger at the back of telehealth this year–but not without a bit of chill

Late last year, this Editor noted that ‘the wind may finally be at the back of telehealth distribution and payment’. The expansion of telehealth access for privately issued Medicare Advantage (MA) plans, state-run Medicaid and CHIP (Children’s Health Insurance Plan) plan members, and this year’s Medicare Physician Fee Schedule, along with a limited expansion of telemedicine in the Value-Based Insurance Design (VBID) model for MA announced earlier this year by CMS, is a leading indicator that government is encouraging private insurers to pay doctors for these services, who in term will pay vendors for providing them.

The Veterans Health Administration (VA) has historically been the largest user in the US of telehealth services (home telehealth, clinical video telehealth, store-and-forward). They are also a closed and relatively inflexible system (disclosure–this Editor worked for Viterion, a former RPM supplier to the VA). In 2017, under then Secretary David Shulkin (who left under a cloud, and not an IT one), there were hopes raised through the Anywhere to Anywhere VA Health Care Initiative. So the news released at the start of HIMSS’ annual meeting that veterans will be able to access their health data through Apple’s Health Records app on the iPhone, perhaps as early as this summer, was certainly an encouraging development. According to mHealth Intelligence, the key in enabling this integration and with other apps in the future is the Veterans Health Application Programming Interface (API), unveiled last year.

Anywhere to Anywhere is also making headway in veteran telemedicine usage. Of their 2.3 million telehealth episodes in their FY 2018, over 1 million were video telehealth visits with veterans, up 19 percent from 2017. 105,000 of those video visits were through VA Video Connect to veterans’ personal devices. The remainder were real-time interactive video conferences at a VA clinic. The other half were assessment of data between VA facilities or data sent from home (the underused Home Telehealth).  Health Data Management

Virginia also moved to make remote patient monitoring part of covered telehealth services for commercial health plans and the state Medicaid program. The combined bills HB 1970 and SB 1221 will be sent for signature to Governor Ralph Northam, to whom the adjective ‘beleaguered’ certainly applies. National Law Review

But service providers face compliance hurdles when dealing with governmental entities, and they’re complex. There are Federal fraud, waste, and abuse statutes such as on referrals (Anti-Kickback, Stark Law on self-referral), state Corporate Practice of Medicine Doctrine statutes, and medical licensure requirements for telehealth practices. Telehealth: The Beginner’s Guide to Legal Pitfalls is a short essay on what can face a medical practice in telehealth.

Medicare Advantage model covering telehealth for certain in-person visits starting in 2020

Another small step for remote monitoring and visits. Late last week, the Center for Medicare & Medicaid Services (CMS) announced a limited expansion of telehealth (remote patient visits) coverage as part of the Value-Based Insurance Design (VBID) model. In 2020, plans can apply to use telehealth as part of their coverage. According to the CMS release, Medicare Advantage (MA) is testing a new series of service delivery approaches, including “increasing access to telehealth services by allowing plans to use access to telehealth services instead of in-person visits, as long as an in-person option remains, to meet a range of network requirements, including certain requirements that could not previously be fulfilled through telehealth.” Other MA additions under the VBID mode include expanded rewards and incentives for beneficiaries for health improvement, and reduced cost sharing and additional benefits to enrollees, including those around chronic conditions or socio-economic status, such as aid around social determinants of health. 

The VBID model is administered under CMS’ Center for Medicare and Medicaid Innovation (Innovation Center, also CMMI), which tests innovative payment and service delivery models to lower costs and improve the quality of care. It began in 2017. The CMS VBID page lists 14 participating plans concentrated in a few states; however, it was open to 25 states this year. The 2020 model expands to 50 states under the Bipartisan Budget Act of 2018 plus will accept other MA plan types such as Special Needs Plans and Regional PPOs. Applications will start later this year. CMS press releasemHealth Intelligence