The release of the Medicare Physician Fee Schedule Final Rule 2018 indicates future potential for using Medicare telehealth services for Chronic Care Management and outreach to patients in hard-to-reach, rural areas by FQHCs and RHCs.
The Medicare Physician Fee Schedule Final Rule 2018 has reinforced the Centers for Medicare and Medicaid Services’ (CMS) ongoing interest in both value-based care and digital health tools, such as using Medicare telehealth services for Chronic Care Management (CCM) purposes. The interest could stem from a push from healthcare providers, who are recognizing the benefits of telehealth in reaching patients for between-visit care with the goal of improved preventive care.
A new add-on code for telehealth has been introduced with this specific case in mind. The HCPCS code G0506 (Care Planning for Chronic Care Management) is for using Medicare telehealth services relating to CCM and care coordination.
Still, a number of barriers exist to the expansion of Medicare telehealth services. One current issue is the confusing regulation of telehealth from state to state, as well as a lack of a centralized definition of telehealth.
The Center for Connected Health Policy stated in its recent State Telehealth Laws and Reimbursement Policies, “No two states are alike in how telehealth is defined and regulated. While there are some similarities in language, perhaps indicating states may have utilized existing verbiage from other states, noticeable differences exist… In most cases, states have moved away from duplicating Medicare’s restrictive telehealth policy, with some reimbursing a wide range of practitioners and services, with little to no restrictions.”
The last state to restrict reimbursement for using Medicare telehealth services to only rural or underserved areas, such as those served by Federally Qualified Health Centers (FQHCs) or Rural Health Centers (RHCs), was New Hampshire. However, it recently lifted this restriction.
Researchers from Humana and Omada Health conducted a study, published in The Journal of Aging and Health, that analyzed 500 participants in Humana’s Medicare Advantage program. The conclusion was that digital health platforms could help cut Medicare costs and improve health outcomes by assisting with management of chronic diseases, such as diabetes, high blood pressure, and heart conditions.
“[S]eniors can be highly engaged in electronic media, which has the potential to greatly expand the number of people these types of programs can help,” said Laura E. Happe, PharmD, MPH, Humana director of research and publications.
The study itself states that Medicare digital health tools and “technology-enabled programs can be delivered asynchronously and on demand, providing flexibility and increased accessibility for those whom fixed, location-based services are impractical.”
In regard to digital health tools, CMS officials stated, "We believe that the use of digital technologies that provide either one-way or two-way data between MIPS eligible clinicians and patients is valuable, including for the purposes of promoting patient self-management, enabling remote monitoring, and detecting early indicators of treatment failure.”
Another highlight of the Medicare Physician Fee Schedule final rule is the “Patients Over Paperwork” initiative, which reinforces current interest among healthcare reformers for more value-based care models rather than the industry’s existing fee-for-service structure. Patients Over Paperwork aims to reduce the burden of reporting and resulting penalties to reimbursements.
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