Telemedicine
is quickly proving itself to be a driving force in the quest to provide broader
access to quality healthcare for more Americans. Expansive mobile technology
advances, faster connection speeds, and President Obama’s ConnectALL initiative have consequently
expanded telemedicine programs through the country and brought this version of
digital medicine to the forefront of many healthcare organizations. One
government entity in particular, The Centers for Medicare and Medicaid Services or
CMS, is recognizing the importance of testing and proving the advantages of
telehealth services for Medicare and Medicaid patients.
CMS’s Innovation Center is working on developing and
implementing new models for Accountable Care Organizations. One of those new
models, based on experiences with Pioneer ACOs and the Medicare Shared Savings Program, the Next Generation ACO model, “sets predictable financial
targets, enables providers and beneficiaries greater opportunities to
coordinate care, and aims to attain the highest quality standards of care.”
However, for MyOnCallDoc, the most innovative part of the Next Generation ACO
model is the Telemedicine Waiver for participating Next Generation
ACOs.
Previous Telemedicine Restrictions
Telemedicine
used to be heavily restricted in many CMS ACOs and payment models. Two regulations initially put in place by CMS made
telehealth unavailable to a wide segment of individuals enrolled in various
ACOs. First, the Rural Health Professional Shortage Areas (HPSA) stipulation geographically
limited which patients could benefit from telemedicine. The HPSAs included “HPSAs
located outside of a county, outside of an MSA [metropolitan statistical area],
as well as those located in rural census tracts, as determined by the Office of
Rural Health Policy.” Individuals residing in these areas experienced shortages
of primary care, dental care, or medical healthcare providers. This regulation
seriously limited the number of patients able to utilize telemedicine
approaches to ongoing healthcare services.
Second, an originating site requirement meant that patients had to travel
to an authorized healthcare facility to initiate a virtual visit with a medical
provider. The originating site designations where Medicare beneficiaries could
receive medical services via telecommunications were:
-
The
office of a physician or practitioner
-
Hospitals
-
Critical
access hospitals (CAH)
-
Rural
health clinics (RHC)
-
Federally
qualified health centers (FQHC)
-
Hospital-based
or critical access hospital-based renal dialysis centers
-
Skilled
nursing facilities (SNF)
-
Community
mental health centers (CMHC).
Additionally,
and even more restricting, most of those originating sites had to be located in
a HSPA or non-MSA location.
MyOnCallDoc
has collaborated with the CMS Seamless Care Models Group at The Center for
Medicare and Medicaid Innovation Centers to increase telemedicine awareness and
access. Through this collaboration, MyOnCallDoc hopes to fully illustrate and
maximize the benefits of telemedicine within the Next Generation ACOs and all
future ACO models. The Innovation Center at CMS is interested in testing
initiatives and models that incorporate innovative approaches to healthcare
without disrupting entire systems. Thus, the Telemedicine Waiver has been developed
to allow for quality testing of telemedicine procedures without changing the
Next Generation ACO model completely.
The Telemedicine Waiver
The
Telemedicine Wavier speaks to the potential future of telemedicine as a part of
a comprehensive, affordable, and effective healthcare system available to
millions of Americans. The Rural Health Professional Shortage Areas regulation
and the originating site requirement for the qualified use of telemedicine have
been expanded within the Telemedicine Waiver. Qualified beneficiaries can now
utilize telecommunications for medical services, which is a testament to the
greater understanding of telehealth benefits. However, as with any new
endeavor, there still exist certain limitations within the Telemedicine Waiver.
The first
limitation outlines allowable originating sites for patients; however, this
regulation has been expanded upon from the list of previously allowed originating
sites. Now, patients can access telemedicine opportunities from their home or
other designated originating sites whether or not they are located in a rural
area. The second limitation within the waiver, excludes certain types of care.
Patients cannot use telehealth services for:
-
Follow-up
inpatient telehealth consultations furnished to beneficiaries in hospitals or
skilled nursing facilities (SNF)
-
Subsequent
hospital care services
-
Subsequent
nursing facility care services.
While the
Telehealth Waiver does not eliminate every barrier to telemedicine services
within Next Generation ACOs, it places telemedicine services at the forefront
of new development models and allows for the growth of telemedicine
opportunities in a variety of healthcare management systems.
MyOnCallDoc and Telehealth Compliant Programs
MyOnCallDoc
has spent significant time with CMS Innovation Centers discussing in detail telemedicine services, clarifying telehealth protocols, uncovering areas for
improvement within particular ACO models, and developing Telehealth Compliant
programs that highlight the potential benefits of incorporating strong
telemedicine initiatives. We have compiled a basic overview of the programs we
will have implemented, they are as follows:
- Chronic Care Management Services: Telemedicine can be used to effectively
manage chronic conditions among an aging population. Medicare created the 99490 code to define how non-face-to-face patient
provider interactions can facilitate the proper management of chronic conditions.
As 2/3 of patients within the Medicare population experience 2 or more chronic
conditions, this program can have far ranging benefits.
- Episodic or Minor Acute Care: Next Generation ACOs have the freedom to
offer telemedicine to their members for the resolution of minor care needs. CMS
statistics cite nearly 60% of urgent care visits could have been managed via
compliant telemedicine services.
- Accurate and Complete Data Collection: Through the use of telemedicine
and specially trained medical staff, a Next Generation ACO can improve the
accuracy and completeness of HCCs and Risk Adjustment Factor data. This
improves an ACOs ability to accurately predict expenditures and receive proper
reimbursement per member.
At MyOnCallDoc, our team is thrilled to be an integral part of the development of telemedicine initiatives for today and the future. The path to implementing telemedicine services in different healthcare management systems will be long, but practioners, administrators, patients, and government entities are beginning to recognize the benefits of incorporating strong telemedicine initiatives, as the healthcare system expands. The Telehealth Waiver for Next Generation ACOs will help provide affordable, effective healthcare services to many more Americans. Through our partnership programs, we will collect more data to inform best practices, increase the ability of ACOs to be profitable, and improve access to quality healthcare for some of the most vulnerable populations.