Peering Beyond the Pandemic into Medicare’s Telehealth Future 

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HERE IS HOW

Many Medicare tools involving telehealth services were made possible by emergency blanket waivers responding to the  Public Health Emergency (PHE) sparked by COVID-19. The primary changes authorized providers to offer telehealth video and audio-only services and to work from their homes while billing from their offices. Hybrid care appears on the rise, providing the flexibility of in-person or telehealth appointments. It also appears that many practitioners and patients are opting for telehealth as their primary care mode, assuring a strong telehealth future funded by Medicare and other payers.

When Will Medicare Coverage for Telehealth Expire? 

The blanket waivers offering Medicare coverage of services delivered via specified telehealth technology are in effect until the Secretary of HHS has declared that the  COVID-19 public health emergency has passed. The latest HHS extension for the PHE is effective through January 11, 2023.

The PHE status is reportedly very likely to continue beyond January, given the new COVID wave and reports from two Biden administration officials. In a letter to the state governors, HHS committed to providing a 60-day notice before the PHE. That notice has not yet been issued. Other updates on the status of HHS declarations of public health emergencies and the effects on telehealth’s future can be assessed through the federal government’s PHE tracker.

PHE’s Impact on Reimbursement for Telehealth Tools by Providers

Medicare is only one of several large telehealth funding sources dependent on the PHE. The PHE allows temporary provisions to allow employers the flexibility to offer telehealth services outside the deductible to employees with High Deductible Health Plans with  Health Savings Accounts (HSAs). Many groups are stepping in to voice concern over the possible loss of these provisions, including the American Telemedicine Association (ATA). In an ATA Action, Kyle Zebley, senior vice president of public policy, American Telemedicine Association, and Executive Director, ATA Action stated:

We certainly appreciate the unprecedented support telehealth has received from the President and Congress, allowing Americans to access needed services during the public health emergency. However, that option will come to a screeching halt for many American workers who have a high deductible health plan (HDHP) health savings account (HSA), who will not be able to access telehealth coverage without first having to meet annual deductibles if Congress does not act urgently before that provision expires on December 31… It would be untenable to think, now that people have come to depend on telehealth for needed care, including telemental health services, that we could allow that benefit to be pulled out from under them, particularly in these challenging economic times.

The ATA is joined by many other groups in urging Congress to extend many of the waivers beyond the PHE. Nebraska-based CHI Health is a regional healthcare network of 28 hospitals, two stand-alone behavioral health facilities, and more than 150 employed physician practices in Iowa, Minnesota, Nebraska, and North Dakota who addressed the issue head-on in a letter to Congress on Nov. 28. It urged them to continue the pandemic-era safe harbor for first-dollar high deductible health plan telehealth coverage.

In the letter, shared with Becker’s Hospital Review, CHI Health urged Congress also to extend safe harbors for telehealth coverage by high-deductible health plans to maintain and expand healthcare access and reduce healthcare burdens on providers into the telehealth future. The letter stated,

Ensuring that Americans can continue to access virtual services is crucial to maintaining and expanding access to care for Americans, whether they are Medicare or HDHP beneficiaries. The sudden unavailability of live video and audio services would force these beneficiaries to travel to healthcare sites to access care in person — a sometimes impossible proposition especially in rural areas — straining providers across the healthcare ecosystem.

Looking to the Telehealth Future

With or without the assistance offered to providers and patients, telehealth tools will continue to be in demand beyond the PHE. According to a recent study by the American Medical Association, providers polled voted “tele-visit” outranked other tools in provider enthusiasm, adoption, and improved patient outcomes compared to other digital health tools. The author’s predicted that the “majority of physicians who have not yet incorporated these tools are seeking to utilize them in the next three years.” From the perspective of innovation and funding, the telehealth future also continues to appear strong.

Regulatory Vision for Easing Out of the  PHE

The Centers for Medicare and Medicaid Services (CMS) has indicated  their indicated released a strategy involving three concurrent phases for assessing which blanket waivers should stay in effect beyond the PHE and into the telehealth future:

1. Evaluating blanket waivers based on the current stage of the PHE as compared to when the waivers were first issued.
2. Keeping tools in place which would be the most helpful in future PHEs, to ensure a rapid response both locally and nationally.
3. Continuing coverage of flexibilities that are aimed at producing high-quality care and health equity. CMS is working with the healthcare industry to holistically prepare our health care system for future PHEs.