What’s New in Telehealth Reimbursements for 2023?

The big question for healthcare organizations that have expanded their telehealth services since the beginning of the pandemic has been what will happen when the public health emergency ends. This uncertainty is what’s known as the “telehealth cliff.”

By authority granted under the Coronavirus Aid, Relief, and Economic Security Act, the Centers for Medicare and Medicaid Services provided flexibility for Medicare telehealth services by broadening the waiver authority under section 1135 of the Social Security Act.

This waived CMS’s geographic and originating site requirements for telehealth reimbursement under Medicare. According to the requirements, the originating site (the patient’s location at the time telehealth services are received) must be a physician’s office, skilled nursing facility or hospital. The patient must also be located within a Health Professional Shortage Area or in a county outside of any Metropolitan Statistical Area (as defined by the U.S. Census Bureau).

The emergency, which had been in effect since Jan. 31, 2020, has been extended by the U.S. Department of Health and Human Services every three months. However, the most recent extension, set to expire on May 11, 2023, was the last.

Fortunately for health IT leaders and patients who rely on telehealth services for healthcare access, in December 2022, congress passed the Consolidated Appropriations Act of 2023, an omnibus appropriations bill that includes a two-year extension of Medicare telehealth waivers in addition to other provisions impacting healthcare.

Updates for Telehealth Reimbursement in 2023

Here is how the passing of the Consolidated Appropriations Act of 2023 will impact healthcare organizations:

• Anywhere the patient is, including their home or temporary residence, will continue to qualify as an originating site for telehealth reimbursement through Medicare.
• Eligible practitioners, including occupational therapists, physical therapists, speech-language pathologists and audiologists, will continue to be qualified to provide telehealth services.
• The rule requiring mental health services to be provided in person has been delayed.
• The Acute Hospital Care at Home program has been extended, which is good news for hospitals that have expanded their hospital-at-home programs and for hospital-at-home companies.
• Safe harbor exceptions have been extended so that telehealth services are covered by high-deductible health plans.

On May 3, 2023, the Drug Enforcement Administration announced that it would extend waivers of the in-person rule mandated by the Ryan Haight Act of 2008, which allows patients to receive prescriptions of controlled substances via a telehealth appointment rather than having to be seen in person. Organizations such as the American Telemedicine Association (ATA) called on the DEA to address the issue. The DEA announced the extension after receiving a record 38,000 comments on its proposed telemedicine rules.

Tips for Re-Evaluating Telehealth Programs Across Organizations

As healthcare organizations begin to feel more comfortable with the long-term viability of their virtual care programs, health IT leaders should begin to look at the technology deployed in the early, chaotic days of the pandemic and create a thoughtful plan.

Many healthcare organizations entered three-year vendor contracts at the beginning of the pandemic. As those contracts come to an end, health IT leaders should assess how those telehealth solutions are working for their clinicians, whether they’re meeting all the organization’s needs and whether there are any gaps that need to be filled.

Now that telehealth waivers have been extended, there will likely be a renewed interest in venture capital. As a result, health IT leaders should consider other telehealth platforms on the market, especially if they implemented several point solutions under duress during the pandemic. It’s healthy for organizations to undergo that assessment exercise.

It’s inefficient for an organization to have different clinical monitoring solutions — which may not talk to each other — across departments. There are no economies of scale in that case. The organization would be servicing individual cohorts rather than the enterprise, which can lead to a fracture in care.

A next step for some organizations could be the launch of a clinical command center or finding ways to integrate virtual care with other aspects of an organization’s care strategy. Doing so requires tight, seamless integrations across application programming interfaces so that a virtual care platform can communicate with the platform being used by the clinical command center, for example. It’s important for healthcare organizations to get the most out of their telehealth platforms by connecting them to other initiatives. This may involve examining integrations with existing investments such as Microsoft Enterprise and Google Cloud.

One way telehealth programs will likely evolve is by moving away from managing dozens of mobile carts to telehealth solutions that are integrated into the patient room. Clinicians should be able to tap into any room at any time. That’s the future of virtual care.

CDW experts can help as organizations look to reassess their telehealth programs. Whether an organization is at the beginning of its virtual care journey and doesn’t know where to start or is midway through its journey and wants to talk about what the future could entail, CDW can help build a roadmap to achieve the organization’s goals.

Even if an organization has a sophisticated virtual care program in place, we’d still like to talk to the health IT team to learn from their experience.

Predictions for the Future of Telehealth Reimbursement

Congress will have to act again before the end of 2024 to make telehealth reimbursement permanent for Medicare recipients. Achieving this will require the ongoing advocacy by industry and industry groups such as the ATA. It’s important to CDW that it continue to work with the ATA to drive that conversation forward together.