In March of this year, the Centers for Medicare and Medicaid Services (CMS) released a telehealth and telemedicine tool kit for long-term care nursing homes. The eight-page document is a collection of links to hundreds more pages of online resources, policy statements regarding COVID-19, checklists, recommendations, and press releases from CMS.
If you are a skilled nursing care facility (SNF) considering launching a telehealth program, it can be a tough pile of material to wade through, especially in the middle of a national health emergency. Not all the material is specific to SNFs (in fact most of it isn’t), and on top of that, some of the links CMS provided in the tool kit have since expired and/or been replaced by more up-to-date material.
Since Daily Care Telemedicine aims to give you “a direct line” to better telemedicine, we’ve taken the time to pull out some of the tool kit’s key takeaways on everything from regulatory challenges to choosing a telemedicine vendor.
Regulatory Changes Impacting SNFs
On March 17th, both CMS and the HHS Office of the Inspector General released a series of policy changes and waivers dramatically expanding the types of telemedicine they would allow and the circumstances in which CMS will reimburse for telemedicine visits.
These are the most sweeping changes:
- Medicare will reimburse for telemedicine visits everywhere, not just in rural areas as before the pandemic.
- Medicare will now reimburse for telehealth services originating anywhere, including a patient’s home. Previously, telehealth had to take place at a qualified “originating site,” (skilled nursing facilities were already included in those).
- Medicare used to require an “established relationship” to exist with the patient receiving telehealth services; the new rules state that CMS will use selective enforcement and not conduct audits to ensure those relationships exist, so long as the public health emergency endures.
- The Office of the Inspector General said that physicians and other healthcare providers can waive any cost-sharing (deductibles and/or co-insurance) for any telehealth visit. Previously, doing so could have been considered a violation of anti-kickback laws.
- Finally, HIPAA violations will not be pursued if you communicate with patients via common consumer communications platforms such as Skype or FaceTime.
The tool kit states explicitly that “nursing homes do not need to apply for a waiver to use telehealth and telemedicine services,” and in fact the presence of COVID-19 means that there is an “urgency to expand” telemedicine in order to keep vulnerable patients safe and healthy.
In other words, the regulatory door is more than open — skilled nursing care facilities just need to walk through it.
Which Telehealth Services Codes Are Covered?
The telehealth and telemedicine tool kit provides a link to the CMS page where you can download an excel list of telehealth services which are currently payable under the Medicare Physician Fee Schedule. CMS keeps the page fairly up to date (the last update as of this piece was on October 14th, 2020).
Here’s a handy summary (via CMS):
Telehealth and Telemedicine Implementation Guides
The tool kit provides links to several implementation and startup guides, including this extremely comprehensive one published as a collaboration between Telligen and gpTRAC (the Great Plains Telehealth Resource Assistance Center), and another published by Washington State.
Unfortunately, both of these are broad in their recommendations for setting up a telehealth program generally, nor are they specific to the needs of skilled nursing facilities. And neither of them were produced in the context of a global pandemic. Thus, they may have out-dated information on regulatory barriers and/or technology overviews.
Those guides also do not take into account the new incentives which should be prompting every SNF without a telemedicine program to immediately begin planning for one. First among these is the need to keep SNF staff and patients alike safe from COVID-19, while continuing to provide quality care.
We recommend using gpTRAC’s “Checklist for Initiating Telehealth Services,” rather than reading through dozens of pages in an out-dated guide. The checklist won’t give you all the answers, but it will make sure you don’t forget to ask any of the important questions which need asking as you prepare for and implement a telehealth program.
Which brings us to:
How to choose a telemedicine vendor
Of course, if you are a skilled care facility, we would love for you to consider Daily Care Telemedicine as your telemedicine provider. We offer enterprise technology combined with a direct line to personalized service for our partners.
That said, the CMS tool kit links to a good overview for choosing a vendor provided by the National Organization of State Offices of Rural Health. Like many of the other resources provided by CMS, this one is a little old (it was uploaded in 2016). Yet it still provides a good set of questions to ask and considerations for choosing a telemedicine services provider:
What the future holds
In March 2020, with COVID-19 a growing threat and our country’s health system responding to it on the fly, we naturally turned to the resources and guides which had been developed over the past 5-10 years. But the roadmaps of the past may not necessarily be the best guides for the future.
Around the country, 2020 has been a watershed year for growth in telemedicine and telehealth. Skilled nursing facilities are no exception. As the epicenters of many early outbreaks, SNFs turned to telehealth as a way to keep its staff and patients safe. As a country and as a healthcare system, we are collectively learning an enormous amount about what works and what doesn’t when it comes to telemedicine implementations.
No doubt by this time next year, we will have even more tools, and better tools, in our collective telemedicine tool kit.
