OHIC Payment and Care Delivery Advisory Committee Telemedicine - - PowerPoint PPT Presentation

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OHIC Payment and Care Delivery Advisory Committee Telemedicine - - PowerPoint PPT Presentation

OHIC Payment and Care Delivery Advisory Committee Telemedicine Subcommittee OCTOBER 8, 2020 Agenda Welcome and Agenda Review 10:00am 10:05am Goals and Process for Developing Consensus-Based 10:05am 10:10am Recommendations Summary


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OHIC Payment and Care Delivery Advisory Committee Telemedicine Subcommittee

OCTOBER 8, 2020

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Agenda

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Welcome and Agenda Review 10:00am – 10:05am Goals and Process for Developing Consensus-Based Recommendations 10:05am – 10:10am Summary of Rhode Island Specific Data 10:10am – 10:40am Discussion of and Public Comment on Payment Parity 10:40am – 11:50am Next Steps and Adjournment 11:50am – 12:00pm

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Goals and Process for Developing Consensus-Based Recommendations

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Telemedicine Advisory Group Goals

Since COVID-19 will continue to be a concern in the coming months, and the need to facilitate access to services through telemedicine persists throughout the duration of the PHE, this group will provide recommendations to Governor Raimondo, Commissioner Ganim and Director Shaffer on potential revisions to emergency telemedicine policies. At the same time, we want to be forward-looking and address:

  • which temporary emergency policies should or should not be carried

forward on a more permanent basis; and

  • how to improve telemedicine as a convenient, cost-effective, accessible

and equitable option for providers and patients in Rhode Island.

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Reminder of Process for Developing Consensus- Based Recommendations

For each policy issue, project staff will share context about the policy choices

  • both internal and external to Rhode Island - including a list of pros and cons.

The group will discuss each issue, including exploring the pros and cons of policy choices, and identifying key concerns, needs and objectives. All participants are welcome to provide input. All draft recommendations will be recorded and emailed to the group in advance of each meeting.

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Reminder of Zoom Meeting Procedures

Please stay muted to reduce background noise and use the “raise hand” feature if you wish to speak. We will keep track of raised hands and call on individuals as time permits.

  • Due to the large number of participants, we may not get to every individual

who raises their hand, but will prioritize a diverse sampling of stakeholders.

  • There will also be a public comment period at the end of each topic area.
  • When called on to speak, please slowly state your name and the
  • rganization you represent prior to commenting or asking a question.
  • You may also use the chat function for general questions to the group.

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New Telemedicine Data

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Patients Like Telemedicine

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Press Ganey surveyed more than 30,000 consumers who used telemedicine in March and April of 2020. “Patients are overwhelmingly positive about their virtual visit interactions with their care providers, even when technical issues posed challenges.”

Source: The Rapid Transition to Telemedicine: Insights and Early Trends. May 19, 2020. Press Ganey.

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Rhode Island-Specific Data

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OHIC requested data from the four largest commercial insurers: BCBSRI, NHP, Tufts, United 20-week comparison: March 23, 2019-August 3, 2019 vs. March 27, 2020-August 7, 2020 In person vs. telemedicine visits by select provider specialty Data limitations:

We did not define provider specialty and so some variation across payers may exist The data were not audited for accuracy

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In Person vs. Telemedicine

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500,000 1,000,000 1,500,000 2,000,000 2,500,000

Total Volume of Visits

Telemedicine In Person March 23, 2019 – August 3, 2019 March 27, 2020 – August 7, 2020

Rhode Island experienced a less than one percent overall drop in visit year over year. Source: RI insurers

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In Person vs. Telemedicine Visits, By Week

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Source: RI insurers

10,000 20,000 30,000 40,000 50,000 60,000 70,000 80,000 90,000

In Person Telemedicine

Telemedicine made up for the early loss of in person care, but the flattened out while in person care resumed.

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In Person vs. Telemedicine Behavioral Health Visits, By Week

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2,000 4,000 6,000 8,000 10,000 12,000 14,000 16,000 18,000 20,000

In Person Telemedicine

Telemedicine has “flattened out” at a higher level for behavioral health.

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Source: Epic Health Research Network. https://www.ehrn.org/telehealth-fad-or-the-future/

RI’s experience may have been better than the nation

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In Person vs. Telemedicine by Age

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200000 400000 600000 800000 1000000 1200000 1400000

2019 2020 2019 2020 2019 2020 2019 2020 2019 2020 2019 2020 0-2 3-5 6-17 18-64 65-74 75+

Visit Volume

Telemedicine In person

The commercial population is significantly skewed toward the 18-64 age bracket and so it’s no surprise they utilized telemedicine more (in terms of volume). The 75+ age bracket had the most significant increase in utilization, though the are a very small portion

  • f the commercially insured.

Source: RI insurers

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National data shows telemedicine usage “flattening”

15 Source: IQVIA Medical Claims Data Analysis 2020, https://www.iqvia.com/-/media/iqvia/pdfs/files/iqvia-covid-19-market-tracking-us.pdf

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In Person vs. Telemedicine by Select Specialty Types

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100,000 200,000 300,000 400,000 500,000 600,000 700,000 2019 2020 2019 2020 2019 2020 2019 2020 Primary Care Specialist Behavioral Health All Other

Telemedicine In person

Year-over-year behavioral health visit volume increased 40% Year-over-year primary care visit volume increased 8%

Source: RI insurers

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Proportion of Visits Provided Via Telemedicine March 27, 2020 – August 7, 2020

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In person; 60% Telemedi cine; 40%

Primary Care

In person 83% Teleme dicine 17%

Specialist

In person 36% Telemedi cine 64%

Behavioral Health

In person 91% Telemedicine 9%

All Other In Person Telemedicine Source: RI insurers

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Payment and Program Integrity

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Telemedicine Payment Parity: Approach to Today’s Conversation

  • 1. Per Commissioner Ganim’s comments during the September 24 meeting, defining

what services are appropriate in statute or regulation is too difficult, rigid and static.

  • When discussing our questions, we will assume that we’re only discussing services for which it is

clinically appropriate to be provided via a telemedicine and recognize that clinical appropriateness will vary by modality.

  • 2. This group will not weigh in on licensure or scope of practice requirements, therefore,

we must assume that the telemedicine services regardless of modality are within the scope of allowable services by the provider.

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Core Question for Telemedicine Parity

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Should identical or substitutable services be paid at the same rates, regardless of modality?

In Person Real-Time Synchronous Audio- Visual Real-Time Audio-Only

During the September 24, 2020 meeting, we began our discussion of telemedicine payment parity. Some meeting participants expressed concern with how the question was being posed and suggested a more nuanced discussion of payment parity for audio-only, audio-visual and behavioral health services. However, some participants disagreed with a more nuanced discussion raising concerns that not treating telemedicine equal to in person will contribute to existing disparities.

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Five Options for Discussion

Recognizing there was no consensus on how to approach this discussion, and hearing a number of possible recommendations, today we will invite discussion and feedback on five possible recommendations. While we have prepared the following 5 options, nothing precludes any meeting participant from:

  • identifying alternative options;
  • modifying existing options, or
  • combining options.

The pros and cons offered are merely suggestions. A pro does not guarantee success and a con could be mitigated by additional strategies. You are welcome to offer alternative pros and cons.

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Five Options for Discussion

  • 1. Parity for equal service, regardless of modality
  • 2. Parity for equal service for audio-visual, with an audio-only differential

allowable

  • 3. Parity for behavioral telehealth services – regardless of modality.

Differentials allowed for medical telehealth services – regardless of modality.

  • 4. Differentials allowed based on modality of care
  • 5. Parity for telemedicine, regardless of modality, with differentials allowed for

providers that do not see patients in person.

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Five Options for Discussion

  • 1. Parity for equal service, regardless of

modality

  • 2. Parity for equal service for audio-visual, with

an audio-only differential allowable

  • 3. Parity for behavioral telehealth services, with

differentials allowed for medical services – regardless of modality

  • 4. Differentials allowed based on modality of

care

  • 5. Parity for telemedicine, regardless of

modality, with differentials allowed for providers that do not see patients in person.

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Pros

  • Would allow for equal pay for equal

work

  • Allows for clinicians to make decisions
  • n what is most clinically appropriate

for the patient without a financial incentives driving decision

  • Allows for patients to choose modality

based on their preference (when clinically appropriate)

  • Allows for Rhode Island based

providers to invest in telemedicine, which can enhance continuity of care

  • Recognizes that telemedicine volume

is important reimbursement for provider sustainability Cons

  • Reduces insurer flexibility to

negotiate rates on behalf of the consumer

  • Does not recognize that

telemedicine companies have lower overhead than a Rhode Island based provider who also has an office-based practice, and therefore may inadvertently increase the profit margins of telemedicine companies who do not provide in person services.

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Five Options for Discussion

  • 1. Parity for equal service, regardless of

modality

  • 2. Parity for equal service for audio-visual, with

an audio-only differential allowable

  • 3. Parity for behavioral telehealth services, with

differentials allowed for medical services – regardless of modality

  • 4. Differentials allowed based on modality of

care

  • 5. Parity for telemedicine, regardless of

modality, with differentials allowed for providers that do not see patients in person.

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Pros

  • Recognizes that audio-visual

services require more of an investment by provider

  • rganization than audio-only,

therefore should be paid at a higher rate

  • Values “face-time” with

patients, giving providers additional information with which to make decisions Cons

  • Does not recognize that

audio-only services require the same amount of clinical decision making and time

  • Potential for inherently

devaluing lower-paid services which may be more conducive to audio only - like some primary care and behavioral health services

  • May increase disparities for

individuals without access to audio-visual technology, or internet access who still require telemedicine support.

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Five Options for Discussion

  • 1. Parity for equal service, regardless of

modality

  • 2. Parity for equal service for audio-visual, with

an audio-only differential allowable

  • 3. Parity for behavioral telehealth services, with

differentials allowed for others – regardless of modality

  • 4. Differentials allowed based on modality of

care

  • 5. Parity for telemedicine, regardless of

modality, with differentials allowed for providers that do not see patients in person.

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Pros

  • Recognizes the significant

proportion of behavioral health visits that occur via telemedicine is an important access point for patients, therefore providing an incentive for providers to continue it beyond the pandemic. Cons

  • Makes a distinction between

the type of service offered for each modality, which does not recognize that

  • ther types of services

require same amount of clinical time and decision making.

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Five Options for Discussion

  • 1. Parity for equal service, regardless of

modality

  • 2. Parity for equal service for audio-visual, with

an audio-only differential allowable

  • 3. Parity for behavioral telehealth services, with

differentials allowed for medical services – regardless of modality

  • 4. Differentials allowed based on modality of

care

  • 5. Parity for telemedicine, regardless of

modality, with differentials allowed for providers that do not see patients in person.

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Pros

  • Gives insurers flexibility to

determine the value of each care modality and negotiate reimbursement in the best interest of its members Cons

  • Suggests that work of clinical

decision-making and documentation is different by modality of care

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Five Options for Discussion

  • 1. Parity for equal service, regardless of

modality

  • 2. Parity for equal service for audio-visual, with

an audio-only differential allowable

  • 3. Parity for behavioral telehealth services, with

differentials allowed for medical services – regardless of modality

  • 4. Differentials allowed based on modality of

care

  • 5. Parity for telemedicine, regardless of

modality, with differentials allowed for providers that do not see patients in person.

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Pros

  • Recognizes that telemedicine

companies have much less

  • verhead than a provider

who also has an office-based practice. Cons

  • Devalues telemedicine

companies, which have been an important tool for insurer

  • fferings
  • Administratively burdensome

to define different types of telemedicine providers and track billing

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Additional Considerations Before Discussion

§ Audio-only telemedicine is rather new, and there seems to be some confusion around what is a separately reimbursable audio-only visit and how to properly code for it. § Unfortunately, this confusion negatively impacts patients and there have been reports of patients getting surprise bills for telephone calls. (Jay Hancock,

NPR April 27, 2020)

§ It is unclear whether CMS will continue to pay for audio-only telemedicine beyond the pandemic. § Regardless of the outcome of the payment parity recommendation, there is a need for future work to provide more clarity on what might be appropriate to bill as a separate audio-only telemedicine visit.

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Final Thoughts Before Discussion

“Telehealth services should be reimbursed on a thoughtful consideration of the value provided and the cost of delivery – as is done with in-person care. Flexibility on the use and reimbursement of these services is essential to maximizing the benefit to patients and the system at large.”

– Taskforce on Telehealth Policy Findings and Recommendations, September, 2020

29 Taskforce on Telehealth Policy Findings and Recommendations, September 2020

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Five Options for Discussion

  • 1. Parity for equal service, regardless of modality
  • 2. Parity for equal service for audio-visual, with an audio-only differential

allowable

  • 3. Parity for behavioral telehealth services – regardless of modality.

Differentials allowed for medical telehealth services – regardless of modality.

  • 4. Differentials allowed based on modality of care
  • 5. Parity for telemedicine, regardless of modality, with differentials allowed for

providers that do not see patients in person.

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Next Steps

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Meeting Schedule

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Meeting Number Meeting Date Meeting Topics 5 October 22, 2020 10:00am – 12:00pm Security, Privacy and Confidentiality 6 November 12, 2020 10:00am – 12:00pm Performance Measurement 7 December 3, 2020 10:00am – 12:00pm Review of Recommendations

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Contact Information

Marea Tumber Marea.Tumber@ohic.ri.gov Chantele Rotolo Chantele.Rotolo@ohhs.ri.gov Olivia King Olivia.King@bhddh.ri.gov Megan Burns mburns@bailit-health.com January Angeles jangeles@bailit-health.com

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