LTPAC organizations that haven’t yet adopted telehealth, or optimized their use of it, but seek to do so, likely have two pressing concerns beyond implementation:

1. How does reimbursement work?
2. Are there any specialized requirements under current regulations?

From a reimbursement standpoint, a LTPAC facility as an originating site can bill $35-$40 in reimbursement for each telehealth session—and can bill that amount for each resident session. While this may not seem like a large sum, it can help to offset the hourly rate cost for staff members and/or aides facilitating each session.

A Centers for Medicare and Medicaid Services (CMS) toolkit states that CMS has broadened access to Medicare telehealth services so that beneficiaries…”can receive a wider range of services from their doctors without having to travel to a healthcare facility. These policy changes build on the regulatory flexibilities granted under the President’s emergency declaration. CMS is expanding this benefit on a temporary and emergency basis under the 1135 waiver authority and Coronavirus Preparedness and Response Supplemental Appropriations Act.”

Under the 1135 waiver, Medicare will pay for office, hospital and other visits furnished via telehealth. As of March 6, 2020, this includes a visit at a patient’s/ resident’s place of residence. Additionally, the HHS Office of Inspector General (OIG) announced in a bulletin that it now provides flexibility for healthcare providers to reduce or waive cost-sharing for telehealth visits that are paid by federal healthcare programs announced in this bulletin.

It’s important to know that, for the duration of the COVID-19 public health emergency, Medicare will reimburse for professional services furnished to beneficiaries in all areas of the country, in all settings. Prior to declaration of this emergency, reimbursement (without a waiver) was only available to healthcare providers located in rural areas of the country.

RELATED RESOURCE: Telehealth for LTPAC Organizations: Best Practices for Enhancing Clinical Outcomes

So, a nursing home located a few minutes away from a hospital wasn’t previously available for telehealth reimbursement by CMS. Now it is—and many industry experts believe it could be for all healthcare providers moving forward, regardless of geographic areas.

Notes on Medicaid and Private Insurance Reimbursement

Generally, Medicaid laws around telehealth vary greatly from state to state—some have laws that spell out telehealth reimbursement policies, while others do not. It’s best to contact your regional telehealth resource center for information about Medicaid policies in your state.

Regarding private insurance, mandates are also administered at the state level—and like Medicaid, some states have laws dictating telehealth reimbursement policies, while others do not. Again, contact your regional telehealth resource center for information.

HIPAA Restrictions Loosened

Currently, HIPAA regulations have been relaxed due to the pandemic. However, it’s important that telehealth visits be conducted over a secure network—and it’s essential that all privacy must be protected. To be safe and help ensure compliance, it’s important for your LTPAC organization to meet the exact same HIPAA requirements, today and tomorrow, while using telehealth as you would if services were being delivered in-person without interactive telehealth equipment and technology. Moreover, states may maintain their own security and privacy laws, so it’s critical to be familiar with those and comply 100%.

That said, the HHS Office for Civil Rights (OCR) plans to exercise enforcement discretion and waive penalties for HIPAA violations against healthcare providers that serve patients in good faith through telehealth technologies during the COVID-19 public health emergency. Even so, we recommend taking all steps necessary to comply with current HIPAA regulations.

Contact Richter’s Clinical Consultants

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