Home Health & Hospice Week

Without direct pay, telehealth data won’t be accurate.

If Medicare officials think home health agencies can furnish telehealth services to patients without funding, they need to think again. So say a chorus of providers in comments on the proposed rule.

“The cost associated with purchasing telehealth technology, developing protocols and training staff is significant. The cost for clinical staff to deliver care via telehealth is significant,” emphasizes Susan Platt, Illinois HomeCare & Hospice Council president, in the state trade association’s comment letter on the 2023 home health proposed rule. “These are all currently unreimbursed expenses that home health agencies cannot continue to absorb,” Platt tells the Centers for Medicare & Medicaid Services.

CMS needs “to recognize the value of services provided using telecommunications technologies,” urges PruittHealth CEO Neil L. Pruitt Jr. in the Norcross, Georgia-based company’s comment letter.

“While many home health agencies are using telecom­munications technology to provide allowed services in some form due to the ongoing pandemic, permanency of telecom­munication technology visits/programs is not feasible for many providers to maintain due to lack of Medicare reimbursement,” warns Texas Association for Home Care & Hospice’s Jennifer Elder in the state association’s comment letter.

“The reality is that Home Health Agencies have made significant investments in telehealth for decades,” highlights Patrick Brown in Michigan in his comment letter. “CMS’s disregard of these expenses is not new.” Telehealth expenses “only accelerated during the pandemic, as patients were reluctant to allow clinicians into their home,” Brown says. “CMS ignores this,” he charges.

“Ignoring telehealth costs is something that needs to be rectified immediately; it is no longer something that CMS can omit,” Brown insists. “CMS reaps the benefit of these programs yet will not acknowledge these costs in calculating the cost of a visit,” he criticizes.

Until CMS pays directly for home health telehealth, it shouldn’t expect data it collects to be worth a whole lot. “The voluntary reporting requirements outlined in the proposed rule will likely provide an inaccurate picture of the overall utilization,” cautions Kim Sisk with CoxHealth at Home based in Springfield, Missouri. “Many providers used telehealth as a supplement to HH visits; however, due to no reimbursement or ability to count the visits towards the LUPA threshold, accurate capture rates and reporting measures may be difficult to obtain,” Sisk warns.

“Home health is not able to fully take advantage of telehealth, as these visits are not recognized in the home health system,” says Cynthia K. Morton with the National Association for the Support of Long-Term Care in the trade group’s comment letter. “NASL strongly supports CMS allowing these telehealth visits to count as visits under the Home Health payment system. Doing so would acknowledge the value of telehealth, the real clinical benefit it provides to patients, and further expand options for high quality patient care,” Morton maintains.

“In 2021, Advocate Aurora provided approximately 800 home health telehealth assessments,” the health system headquartered in Milwaukee and Downers Grove, Illinois, tells CMS. “We believe telehealth services can enhance episodic care for home health patients and urge CMS to permanently reimburse telehealth encounters equivalent to in-home or in-person visits,” execs Meghan Woltman and Denise Keefe relate.

CMS recognizes telehealth costs for other provider types, points out accountant John Reisinger with Innovative Financial Solutions for Home Health in Tampa Florida. “To not allow this service (at any level) for the home health industry, while allowing it for other segments of the Medicare benefit would seem to be injudicious at best, and could possibly be construed as systemically biased against home health,” Reisinger warns. “This must change,” he exhorts.