TELEHEALTH REIMBURSEMENT 2018 Kentucky Telehealth Summit May 24, - - PowerPoint PPT Presentation

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TELEHEALTH REIMBURSEMENT 2018 Kentucky Telehealth Summit May 24, - - PowerPoint PPT Presentation

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TELEHEALTH REIMBURSEMENT 2018 Kentucky Telehealth Summit May 24, 2018 Mei Wa Kwong, JD 877-707-7172 Mario Guttierez CENTER FOR CONNECTED HEALTH POLICY June 2015 CENTER FOR CONNECTED HEALTH POLICY Executive Director cchpca.org Executive

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June 2015 CENTER FOR CONNECTED HEALTH POLICY Mario Guttierez

Executive Director

TELEHEALTH REIMBURSEMENT

2018 Kentucky Telehealth Summit May 24, 2018

877-707-7172 cchpca.org

CENTER FOR CONNECTED HEALTH POLICY

Mei Wa Kwong, JD

Executive Director

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June 2015 CENTER FOR CONNECTED HEALTH POLICY Mario Guttierez

Executive Director

DISCLAIMERS

  • Any information provided in today’s talk is not to be

regarded as legal advice. Today’s talk is purely for informational purposes.

  • Always consult with legal counsel.
  • CCHP has no relevant financial interest, arrangement,
  • r affiliation with any organizations related to

commercial products or services discussed in this program.

CENTER FOR CONNECTED HEALTH POLICY

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June 2015 CENTER FOR CONNECTED HEALTH POLICY Mario Guttierez

Executive Director

CCHP is an independent, public interest organization that strives to advance state and national telehealth policies that promote better systems of care improved health outcomes and provide greater health equity of access to quality, affordable care and services.

CENTER FOR CONNECTED HEALTH POLICY

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June 2015 CENTER FOR CONNECTED HEALTH POLICY Mario Guttierez

Executive Director

CENTER FOR CONNECTED HEALTH POLICY

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June 2015 CENTER FOR CONNECTED HEALTH POLICY Mario Guttierez

Executive Director

CENTER FOR CONNECTED HEALTH POLICY Current Laws, Regulations, Pending Bills State & Federal Interactive Policy Map

TELEHEALTH STATE-BY-STATE POLICIES, LAWS & REGULATIONS

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June 2015 CENTER FOR CONNECTED HEALTH POLICY Mario Guttierez

Executive Director

CENTER FOR CONNECTED HEALTH POLICY

MEDICARE

  • Medicare beneficiaries in rural HPSAs may receive care

via telehealth

  • Practitioner required to be w/patient during consult
  • Consulting & Referring physicians share fee (75/25)

Balanced Budget Act

  • f 1997
  • Included non-MSA sites
  • Eliminated fee sharing
  • Expanded eligible services for reimbursement

Benefits Improvement & Protection Act 2000

  • Expanded list of facilities that may act as an
  • riginating (patient location) site

Medicare Improvements for Patients & Providers Act, 2008

  • Credentialing & Privileging Regulations
  • Increase in number of codes reimbursed
  • Redefinition of “rural”
  • Inclusion of Chronic Care Management Codes

Various Changes Made Administratively

Medicare telehealth policy very limited & has not changed much in recent years

HISTORY OF FEDERAL TELEHEALTH POLICY

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June 2015 CENTER FOR CONNECTED HEALTH POLICY Mario Guttierez

Executive Director

MEDICARE

CENTER FOR CONNECTED HEALTH POLICY

SOCIAL SECURITY ACT OF 1835(m) or 42 USC 1395m

  • Only Live Video reimbursed
  • Store & Forward (Asynchronous) only for Alaska & Hawaii

demonstration pilots

  • Specific list of providers eligible for reimbursement
  • Limited to rural HPSA, non-MSA, or telehealth

demonstration projects

  • Limited types of facilities eligible
  • Limited list of reimbursable services, but CMS decides what

can be delivered via telehealth and reimbursed

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June 2015 CENTER FOR CONNECTED HEALTH POLICY Mario Guttierez

Executive Director

MEDICARE

CENTER FOR CONNECTED HEALTH POLICY

ELIGIBLE PROVIDERS ELIGIBLE SITE (FACILITY)

  • Physicians
  • Nurse practitioners
  • Physician assistants
  • Nurse midwives
  • Clinical nurse specialists
  • Certified registered nurse

anesthetists

  • Clinical psychologists & clinical

social workers

  • Registered dietitians or nutrition

professionals

  • Offices of physicians or

practitioners

  • Hospitals
  • Critical Access Hospitals
  • Rural Health Clinics
  • Federally Qualified Health

Centers

  • Hospital-based or CAH-based

renal dialysis centers (including satellites)

  • Skilled Nursing Facilities
  • Community Mental Health

Centers

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June 2015 CENTER FOR CONNECTED HEALTH POLICY Mario Guttierez

Executive Director

MEDICARE REIMBURSED SERVICES

CENTER FOR CONNECTED HEALTH POLICY

SERVICE HCPCS CODE CPT CODE Telehealth consultations, emergency department or initial inpatient G0425-G0427 Follow-up inpatient telehealth consultations furnished to beneficiaries in hospitals or SNFs G0406-G0408 Office or other outpatient visits 99201-99215 Subsequent hospital care services, w/limitation of 1 telehealth visit every 3 days 99231-99233 Subsequent nursing facility care services, w/limitation of 1 telehealth visit every 30 days 99307-99310 Individual and group kidney disease education services G0420-G0421 Individual & group diabetes self-management training services w/min. 1 hour of in-person instruction in initial year training period to ensure effective injection training G0108-G0109 Individual & group health & behavior assessment & intervention 96150-96154 Individual psychotherapy 90832-90834, 90836-90838 Telehealth Pharmacologic Management G0459 Psychiatric diagnostic interview examination 90791-90792 ESRD-related services included in the monthly capitation payment 90951-90952, 90954-90955, 90957-90958, 90960-90961 ESRD-related services for home dialysis per full month for patients <2 years to 19 includes monitoring for nutrition, growth & development & counseling of parents 90963-90965 ESRD-related services for home dialysis per full month patients 20 & older 90966 Individual & group medical nutrition therapy G0270 97802-97804 Neurobehavioral status examination 96116 Smoking cessation services G0436-G0437 99406-99407 Alcohol and/or substance (other than tobacco) abuse structured assessment & intervention services G0396-G0397

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June 2015 CENTER FOR CONNECTED HEALTH POLICY Mario Guttierez

Executive Director

MEDICARE REIMBURSED SERVICES

CENTER FOR CONNECTED HEALTH POLICY

Annual alcohol misuse screening, 15 minutes G0442 Brief face-to-face behavioral counseling for alcohol misuse, 15 minutes G0443 Annual depression screening, 15 minutes G0444 High-intensity behavioral counseling to prevent sexually transmitted infection; face-to-face, individual, includes: education, skills raining & guidance, performed semi-annually, 30 minutes G0445 Annual, face-to-face intensive behavioral h therapy for cardiovascular disease, individual 15 minutes G0446 Face-to-face behavioral counseling for obesity, 15 minutes G0447 Transitional care management services w/moderate medical decision complexity (face-to-face w/in 14 days of discharge 99495 Transitional care management services w/high medical decision complexity (face-to-face visit w/in 7 days of discharge) 99496 Psychoanalysis 90845 Family psychotherapy w/o the patient present 90846 Family psychotherapy (conjoint psychotherapy w/patient present) 90847 Prolonged service in office or other outpatient setting requiring direct patient contact beyond the usual service; first hour & additional 30 minutes 99354, 99355 Prolonged service in inpatient or observation setting requiring unit/floor time beyond usual service, first hour & each additional 30 minutes 99356, 99357 Annual Wellness Visit, first visit & subsequent visit G0438, G0439

Approximately 80 codes reimbursed if provided via telehealth out of 10,000 possible codes

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June 2015 CENTER FOR CONNECTED HEALTH POLICY Mario Guttierez

Executive Director

NEW CHRONIC CARE MANAGEMENT CODE

  • 2015 Medicare Physician Fee Schedule Final Rule

– Pays for chronic care management code 99490

  • Non face-to-face services
  • At least 20 minutes of clinical staff time directed by a physician or
  • ther qualified health care professional, per calendar month, with

the following elements:

– Multiple chronic conditions expected to last at least 12 months or until death – Chronic conditions place the patient at significant risk of death, acute exacerbation/decompensation or functional decline – Comprehensive care plan established, implemented, revised or monitored.

CENTER FOR CONNECTED HEALTH POLICY

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June 2015 CENTER FOR CONNECTED HEALTH POLICY Mario Guttierez

Executive Director

CCM AND REMOTE PATIENT MONITORING

  • 2017 Medicare Physician Fee Schedule

– Finalized additional Codes for complex CCM

  • 99487 and 99489
  • CMS issued a toolkit to raise awareness
  • 2018 Medicare Physician Fee Schedule

– Unbundled remote monitoring code 99091

  • “collection and interpretation of physiologic data (e.g., ECG, blood

pressure, glucose monitoring) digitally stored and/or transmitted by the patient and/or caregiver to the physician or other qualified health care professional, qualified by education, training, licensure/regulation (when applicable) requiring a minimum of 30 minutes of time.”

CENTER FOR CONNECTED HEALTH POLICY

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June 2015 CENTER FOR CONNECTED HEALTH POLICY Mario Guttierez

Executive Director

RPM CODE REQUIREMENTS

  • Patient Consent
  • Face-to-face visit with the patient (e.g., an annual wellness visit or

physical) required.

  • Reported no more than once in a 30-day period per patient.
  • The service must include the physician or other qualified health care

professional time involved with data accession, review and interpretation, modification of care plan as necessary (including communication to patient and/or caregiver), and associated documentation.

  • CPT 99091 can be billed once per patient during the same service period

as CCM services, TCM services, and behavioral health integration services.

  • Typical telehealth restrictions don’t apply, because doesn’t fall under

Medicare’s definition.

CENTER FOR CONNECTED HEALTH POLICY

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June 2015 CENTER FOR CONNECTED HEALTH POLICY Mario Guttierez

Executive Director

MEDICARE ADVANTAGE

  • Beginning 2020 – MA plans allowed to provide “additional telehealth

benefits”

  • Treated the same as Medicare fee-for-service option
  • Additional telehealth benefits include:
  • Part B benefits without restrictions
  • Other services identified as clinically appropriate
  • HHS Secretary must solicit comments on types of telehealth services that

should be considered additional telehealth benefits by Nov. 30, 2018.

  • Secretary shall establish requirements around:
  • Physician or practitioner licensure
  • Care coordination with in-person services
  • Other areas specified by the Secretary

CENTER FOR CONNECTED HEALTH POLICY

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June 2015 CENTER FOR CONNECTED HEALTH POLICY Mario Guttierez

Executive Director

ACCOUNTABLE CARE ORGANIZATIONS

  • Beginning 2020 ACOs have the ability to expand

telehealth services by:

  • Including home as originating site
  • Eliminating geographic requirements
  • The Secretary required to conduct study on utilization

and expenditures for telehealth by applicable ACOs and report to Congress no later than Jan. 1, 2026.

  • Similar waiver made in:
  • Next Generation ACO
  • Comprehensive Care for Joint Replacement Model

CENTER FOR CONNECTED HEALTH POLICY

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June 2015 CENTER FOR CONNECTED HEALTH POLICY Mario Guttierez

Executive Director

ACUTE STROKE AND END STAGE RENAL DISEASE

  • Beginning Jan. 1, 2019, the following sites are eligible originating

sites and exempt from the rural geographic requirement, but NOT eligible for the facility fee: ESRD-related visits

  • Renal dialysis facility *
  • Hospital based or CAH based renal dialysis center
  • Home (in-person visit 1/month)*

Acute Stroke Treatment

  • Hospital
  • CAH
  • Mobile Stroke Unit*
  • Any site determined appropriate by the Secretary*

* Not currently an eligible originating site.

CENTER FOR CONNECTED HEALTH POLICY

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June 2015 CENTER FOR CONNECTED HEALTH POLICY Mario Guttierez

Executive Director

FEDERAL UPDATE

CENTER FOR CONNECTED HEALTH POLICY

  • Current Legislation

– Opioid bill passes Senate Health Panel – Opioid Crisis Response Act of 2018 (S 2680) – Makes changes to Ryan Haight

  • Requires DEA to register community mental health or addiction

treatment centers as eligible patient site for initial controlled substances prescription.

  • Forces DEA to create special registration to prescribe via telehealth

without an in-person exam – Existing legislation that continues to look at expanding the utilization of telehealth, but has not moved – HR 5603 (Matsui) - Access to Telehealth Services for Opioid Use Disorders Act – For treatment of SUD waive certain telehealth limitations under Medicare around originating site, geography and S&F. – VA legislation passed Senate but remains in the House – House introduced VA Mission Act of 2018

  • VA proposed regs

– RAND ECHO report

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June 2015 CENTER FOR CONNECTED HEALTH POLICY Mario Guttierez

Executive Director

2018 LEGISLATIVE TRENDS

8% 11% 11% 16% 19% 6% 12% 13% 4%

2018 State Legislation So Far

Broadband Licensing Miscellaneous Medicaid Reimbursement Pilots Prescribing Practice Standards Private Payer Worker's Comp

CENTER FOR CONNECTED HEALTH POLICY

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June 2015 CENTER FOR CONNECTED HEALTH POLICY Mario Guttierez

Executive Director

As of April 2018

CENTER FOR CONNECTED HEALTH POLICY

45 states

have a definition for telemedicine

36 states

(and DC) have a definition for telehealth

1 states

Alabama has no definition for either

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June 2015 CENTER FOR CONNECTED HEALTH POLICY Mario Guttierez

Executive Director

MEDICAID REIMBURSEMENT BY SERVICE MODALITY

Live Video

49 states and DC

Store and Forward

Only in 15 states

Remote Patient Monitoring

20 states

As of April 2018

CENTER FOR CONNECTED HEALTH POLICY

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June 2015 CENTER FOR CONNECTED HEALTH POLICY Mario Guttierez

Executive Director

PARITY IN PAYMENT WITH IN-PERSON

38 states and DC

have telehealth private payer laws

This is the most common policy change at the state level!

Parity is difficult to determine:

  • Parity in services covered vs. parity in payment
  • many states make their telehealth private payer laws

“subject to the terms and conditions of the contract”

As of April 2018

Some go into effect at a later date.

CENTER FOR CONNECTED HEALTH POLICY

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June 2015 CENTER FOR CONNECTED HEALTH POLICY Mario Guttierez

Executive Director

KENTUCKY TELEHEALTH POLICY

CENTER FOR CONNECTED HEALTH POLICY

  • MEDICAID
  • Only Live Video reimbursement
  • Coverage is limited to:

 Consultation  Mental health evaluation and management services  Individual and group psychotherapy  Pharmacologic management  Psychiatric/psychological/mental health diagnostic interview examinations  Individual medical nutrition services  Individual diabetes self-management training*  Occupational Therapy evaluation or treatment (provided by OTs)  Physical therapy evaluation or treatment (provided by PTs)  Speech therapy evaluation or treatment (provided by speech therapist)  Neurobehavioral status examination*  End-stage renal disease monitoring, assessment or counseling consultation*

* Certain restrictions apply All telehealth services are subject to utilization review.

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June 2015 CENTER FOR CONNECTED HEALTH POLICY Mario Guttierez

Executive Director

KENTUCKY TELEHEALTH POLICY

CENTER FOR CONNECTED HEALTH POLICY

  • MEDICAID
  • Providers must be approved through the Kentucky e-Health Network Board. Must be

approved member of KY telehealth network.

  • Eligible providers for services NOT in a Community Mental Health Center:

 A psychiatrist;  A licensed clinical social worker;  A psychologist;  A licensed professional clinical counselor;  A licensed marriage and family therapist;  A physician*;  An APRN*;  Speech-language pathologist*;  Occupational therapist*;  Physical therapist*;  Licensed dietitian or certified nutritionist*; or  Registered nurse or dietician* * Certain restrictions apply.

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June 2015 CENTER FOR CONNECTED HEALTH POLICY Mario Guttierez

Executive Director

KENTUCKY TELEHEALTH POLICY

CENTER FOR CONNECTED HEALTH POLICY

  • MEDICAID

Eligible providers for services in a Community Mental Health Center:

  • A psychiatrist;
  • A physician;
  • Psychologist with a license in accordance with KRS 319.010(5);
  • A licensed marriage and family therapist;
  • A licensed professional clinical counselor;
  • A psychiatric medical resident;
  • A psychiatric registered nurse;
  • A licensed clinical social worker;
  • An advanced practice registered nurse
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June 2015 CENTER FOR CONNECTED HEALTH POLICY Mario Guttierez

Executive Director

KENTUCKY TELEHEALTH POLICY

CENTER FOR CONNECTED HEALTH POLICY

  • MEDICAID – Informed Consent

Before providing a telehealth consultation, providers must document written patient informed consent. This includes:

  • The patient may refuse the telehealth consultation at any time without affecting

the right to future care or treatment, and without risking the loss or withdrawal of a benefit to which the patient is entitled;

  • The recipient shall be informed of alternatives to the telehealth consult;
  • The recipient shall have access to medical information resulting from the

telehealth consult as provided by law;

  • The dissemination, storage, or retention of an identifiable recipient image or
  • ther information from the telehealth consult shall comply with all state and

federal confidentiality laws and regulations;

  • The patient shall have the right to be informed of the parties who will be present

at the spoke site and the hub site during the telehealth consult, and shall have the right to exclude anyone from either site;

  • The patient shall have the right to object to the videotaping of a telehealth

consult.

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June 2015 CENTER FOR CONNECTED HEALTH POLICY Mario Guttierez

Executive Director

KENTUCKY TELEHEALTH POLICY

CENTER FOR CONNECTED HEALTH POLICY

  • SB 112
  • Changes KY Medicaid Telehealth Policy
  • Not in effect until July 1, 2019

 Allows Store & Forward  Reimbursement rates will be established by the Cabinet for Health and Family Services  Still maintains no fax, email, phone

  • Changes KY Private Payer Telehealth Policy
  • Not in effect until July 1, 2019

 Allows Store & Forward  Coverage for service and amount paid same as in-person UNLESS  Providers and plans can agree contractually to pay at a lower rate than would have been charged in-person  Would not require a provider to be part of a telehealth network Does not allow telehealth to be used in abortion.

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June 2015 CENTER FOR CONNECTED HEALTH POLICY Mario Guttierez

Executive Director

THANK YOU!

MEIK@CCHPCA.ORG