Last week a presentation from the Medicare Payment Advisory Commission (MEDPAC) surfaced, presenting policy options for expanding telehealth in Medicare. MEDPAC is a nonpartisan legislative branch agency that provides the US Congress with analysis and policy advice on the Medicare program.  The presentation starts by putting the current telehealth policy environment into perspective, with bullet points on how providers have rapidly adopted telehealth during the public health emergency (PHE), and how health advocates assert that telehealth can expand access to care and reduce costs.  However, on the flip side telehealth has been recently implicated in fraud cases and current evidence on how telehealth services impact quality of care is limited and mixed, according to the slides.  The policy options for permanent telehealth expansions made in the presentation were at least partially based on focus groups with beneficiaries and clinicians conducted throughout the summer, and focus on telehealth expansions for fee-for-service (FFS) clinicians only after the PHE.  

MEDPAC presents the following policy options, along with the rationale behind the policy option being presented on each slide:

  • Cover certain telehealth services provided to all beneficiaries and in the beneficiaries’ home, as this was supported by focus groups as long as there is a balance of in-person visits as well.
  • Cover many, but not all, of the telehealth services paid for during the PHE, specifically those services for which access is limited or do not reduce quality of care, such as mental health.
  • Eliminate temporary coverage of audio-only services after the PHE.  This is because, according to the slide, it is difficult to conduct a full exam without seeing the patient, and they predict this will likely lead to additional services and increased spending.
  • Pay lower rates for telehealth services than for in-person services, as telehealth services probably involve lower practice costs than in-person services.
  • Require HIPAA compliance for telehealth technology, in order to protect patient privacy and reduce the risk of identity theft.
  • Require cost sharing for telehealth services, as this could reduce the possibility of overuse.

Other safeguards that could protect Medicare and beneficiaries from unnecessary spending and potential fraud include:

  • Study whether to set frequency limits for certain telehealth services.
  • Require clinicians to provide a face-to-face visit before they order high-cost durable medical equipment (DME) and clinical lab tests.
  • Prohibit ‘incident to’ billing for telehealth services provided by any clinician who can bill Medicare directly.
  • Prohibit clinicians from billing ‘incident to’ services if they provide direct supervision remotely.

These are only policy options presented by MEDPAC, and not necessarily Medicare’s policy moving forward.  For more details, see the full presentation.  To see what Medicare has outlined in their 2021 proposed Physician Fee Schedule (PFS), see CCHP’s factsheet and the PFS full text, and stay tuned for the final fee schedule expected to be released in the coming weeks.

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