Easing staffing woes is an important plus. With the benefits of telehealth for home health patients plentiful, why hasn’t Medicare started paying for it directly? That’s one of the many questions posed by commenters on the 2023 home health proposed rule. Recap: In its 2023 rule published in the June 23 Federal Register, the Centers for Medicare & Medicaid Services floats the idea of collecting telehealth data on home health claims. CMS aims to begin collecting data by Jan. 1, 2023, on a voluntary basis, then on a mandatory basis by July 2023. “Collecting data on the use of telecommunications technology on home health claims would allow CMS to analyze the characteristics of the beneficiaries utilizing services furnished remotely, and could give us a broader understanding of the social determinants that affect who benefits most from these services, including what barriers may potentially exist for certain subsets of beneficiaries,” the agency says in its fact sheet about the rule. “Specifically, we are soliciting comments on the use of three new G-codes” for telehealth reporting, CMS details in the rule. The new codes would represent three scenarios — “when home health services are furnished using synchronous telemedicine rendered via a real-time two-way audio and video telecommunications system; synchronous telemedicine rendered via telephone or other real-time interactive audio-only telecommunications system; and the collection of physiologic data digitally stored and/or transmitted by the patient to the home health agency, that is, remote patient monitoring,” according to the rule (see HCW by AAPC, Vol. XXXI, No. 22-23). Home health providers and their representatives share many positives of telehealth in the home health setting in many of the 900 comment letters CMS has received about the rule. Gunderson Health System in La Crosse, Wisconsin “fully supports the further integration and use of telehealth in patient care,” health system officials say in the system’s comment letter on the proposed rule. “We have seen great advantages in using these services for our patients as they have easier access to care and support from our medical staff,” they say. “Patients are able to get easier answers to questions and receive updates to their care plan,” they add. “Trinity Health at Home has long been a provider of Remote Patient Monitoring for our patients on Home Health service,” reports Trinity Health’s Donna Wilhelm in the Livonia, Michigan-based health system’s comment letter. “This tool benefits patients and clinicians by providing real-time communication and data for patients who otherwise would be high utilizers of the Emergency Department or Inpatient Hospitalization, which decreases the cost of care and saves Medicare and Medicaid dollars,” Wilhelm highlights. Dallas-based chain AccentCare Inc. offers stats to back up the rehospitalization and emergency department claim. The company “partnered with Brittain-Kalish Group to study the quality and satisfaction levels for hybrid home health care, a mix of in-person and telehealth virtual visits,” AccentCare’s Stacey Smith explains in its comment letter. That study found “only 8.6 percent of patients who received hybrid home health were hospitalized within 30 days after starting care, while 14.3 percent of patients who received traditional home health were hospitalized within that same time period,” she points out.
Bottom line: “For home health providers, telecommunications technology use has resulted in significantly fewer hospitalizations” for patients, stresses Texas Association for Home Care & Hospice’s Jennifer Elder in the state association’s comment letter on the rule. Patient outcomes are better in other areas, too, commenters point out to CMS. In the AccentCare study, “medication management of oral medications was better in the hybrid care group than the traditional care group (+4.0 percent),” Smith adds. And “ambulation and locomotion in the home had the highest single improvement in the hybrid care group over the traditional care group (+5.5 percent), demonstrating merit for improving gross motor safety and function at home,” she also highlights. Telehealth has led to “substantial improvement across an array of measures, including medication management, ambulation, and pain mitigation,” TAHC&H’s Elder says. Patients Want Telehealth Too In addition to improving outcomes, home health telehealth helps ease one of the biggest pain points for HHAs right now — staffing. And that helps maintain access to home health services. “Our members have shared that … telehealth … has extended staff resources during the most significant staffing crisis aging service providers have faced,” emphasizes Leading Age’s Katy Barnett in the trade group’s comment letter. “Examples include nursing staff performing care plan oversight using telehealth services while they quarantine for COVID-19 infections, using telehealth for triage situations, and to extend weekend and overnight staffing capabilities.” Likewise, “therapists exposed to COVID-19 and in quarantine are still able to care for patients utilizing telehealth technology,” notes Cynthia K. Morton with the National Association for the Support of Long-Term Care. NASL is an advocacy organization comprised of companies that furnish services such as therapy to home health and other settings. That help with the staffing crunch is especially important for rural providers, notes Johanna L. Beliveau, CEO for the Visiting Nurse and Hospice for Vermont and New Hampshire agency, in her comment letter. “We have leveraged the telehealth allowances to maintain continuity of care and care coordination as well as protect our providers and our patients during the pandemic,” Beliveau tells CMS. “Our rural location increases the travel time between patients, and the potential for unsafe travel conditions based on time of year and season,” Beliveau relates. “Telehealth — when used appropriately — provides an alternative means of access to our patients and enhances the safety of our health care providers,” she says. Telehealth is important “particularly in rural areas of the country where workforce and geographic considerations limit the number of in-home visits that may be possible,” Beliveau concludes. And home health patients actually want telehealth visits, maintains Advocate Aurora health system. “An internal survey of 886 of our patients conducted August 2021 revealed that there is a strong interest in using a mix of in-person and audio/visual home care services,” say execs Meghan Woltman and Denise Keefe in the health system’s comment letter. And a majority of the Advocate Aurora home health patients surveyed, 74 percent, “are very satisfied or somewhat satisfied with their virtual health visits,” Woltman and Keefe relay. Plus “our survey showed that a majority (66 percent) find the ability to have a caregiver or family member join the telehealth visit appealing,” they reveal. Note: The 84-page final rule is at www.govinfo.gov/content/pkg/FR-2022-06-23/pdf/2022-13376.pdf.