Home Health & Hospice Week

Agencies need direct payment for telehealth visits.

Home health agencies are grateful that Medicare officials are loosening up regulations that tie agencies’ hands in providing safe care during the COVID-19 outbreak — but a major obstacle remains.

Good news: The Centers for Medicare & Medicaid Services’ Home Health Prospective Payment System final rule in 2019 made clear that HHAs can provide telehealth services such as remote monitoring, CMS notes in its new interim final rule implementing a host of regulatory changes to help providers deal with the novel coronavirus pandemic.

Bad news: Home health telehealth services must not “substitute for in-person home health services ordered as part of a plan of care certified by a physician.” And “we remain statutorily-prohibited from paying for home health services furnished via a telecommunications system if such services substitute for in-person home health services ordered as part of a plan of care and for paying directly for such services under the home health benefit,” reiterates the interim final rule released March 30.

CMS explains in the rule that it is amending regulations to clarify that:

• “the use of technology must be related to the skilled services being furnished by the nurse/ therapist/therapy assistant,”
• “the use of technology must be included on the home health plan of care along with a description of how the use of such technology will help to achieve the goals outlined on the plan of care without substituting for an in-person visit as ordered on the plan of care,” and
• “on an interim basis HHAs can report the costs of telecommunications technology as allowable administrative and general (A&G) costs by identifying the costs using a subscript between line 5.01 through line 5.19.”

A little leeway: While CMS confirms that “services furnished via a telecommunications system cannot be considered a home health visit for purposes of eligibility or payment,” it does “acknowledge that the use of such technology may result in changes to the frequency or types of visits outlined on the plan of care, especially to combat the PHE for the COVID-19 pandemic.”

National Association for Home Care & Hospice President William Dombi lauds the rule’s “expanded opportunities to combine telehealth services with in-person visits to patients.”

Other helpful telehealth provisions in the rule include allowing visits to patients who have audio capabilities only and expanding access to telehealth services for people with Medicare.

But CMS needs to do better on the telehealth front, industry members insist.HHAs need direct reimbursement for telehealth visits from Medicare, says Melinda Gaboury with Healthcare Provider Solutions in Nashville.

“Home health agencies cannot afford to provide the care for free,” Dombi insists.

At least CMS has clarified that physicians’ telehealth visits can serve as face-to-face encounters for home health certification purposes (see Eli’s HCW, Vol. XXIX, No. 11).

Keep in mind: Many health care observers predict that the liberalized use of telehealth visits at this time will lead to an increased usage — and cost savings — after the pandemic subsides. But new survey results may contradict that idea.

Business and technology consulting firm West Monroe Partners surveyed 3,000 consumers in Chicago, Seattle, and Minneapolis. Of those who said they weren’t open to telemedicine, an average of 46 percent believe it doesn’t provide the same level of care as in-person visits.

Note: The 221-page interim final rule is at www.cms.gov/files/document/covid-final-ifc.pdf.