Telemedicine and COVID-19: Develop an Urgent Response with Sustainable Operational Value

Like most Americans, our team of consultants is quickly adjusting to the new reality created by the COVID-19 global pandemic. All industries are significantly affected, but the most severe impact of this crisis is on the healthcare field, with a surging flow of new public health guidelines, emergency management plans, healthcare reimbursement shifts, and strategies to treat patients effectively without spreading the virus.

Last week, Richard Romero highlighted some of these shifting strategies and reimbursement guidelines in his blog post, “The Role of Telehealth in the Fight Against COVID-19.” Today, we will continue the telehealth dialogue with additional insights for organizations considering operational adjustments and rapid deployment of technology in response to the coronavirus crisis. Additionally, we will direct attention to some of the new guidelines released since our last post. Based on recent reports, healthcare providers across the country are rushing to deploy telehealth initiatives that would have previously taken months or even years of planning. These initiatives are moving quickly due to the urgent need for providers to generate additional capacity for COVID-19 patients while continuing to manage all other patient care safely.

The demand for additional capacity and recent easing of regulatory guidelines for telehealth delivery and reimbursement have ignited the growth of a market that was already projected, before COVID-19, to reach roughly $130 billion by 2025. The current environment is prompting many provider organizations to expedite a decision regarding telehealth services. We encourage organizations that have not previously developed a telehealth business plan to be responsive while also pursuing a thoughtful, collaborative, and sustainable strategy to the extent possible. If your organization is ready to review and compare multiple telehealth vendors, consider the following telemedicine contract must-haves from our recent white paper. The agreement must have:

• A written guarantee to comply with all government mandates.
• An acceptance period (set of conditions to be met before the financial obligation is accepted).
• Comply with the Anti-Kickback Statute.
• Comply with the Beneficiary Inducement Statute and Civil Monetary Penalties Law.
• Comply with the Stark Law (ensure all software and equipment are included in the FMV/CR review).
• Comply with state-specific corporate practice of medicine rules.
• A non-solicitation clause(s).

The Telehealth Initiative offers a Telemedicine Vendor Evaluation tool, a list of Telemedicine Vendor Options, along with free online access to several other resources to help physicians implement telehealth services. These resources are available at the American Medical Association website.Many organizations do not have the time or previous telemedicine experience to reference when rapidly deploying this new service. Therefore, we also recommend becoming familiar with the recently issued Telemedicine Tool Kit from CMS. Below are a few highlights along with some considerations from our team:

As you develop a more comprehensive plan to manage COVID-19, we also recommend addressing the following:

• Clinical quality and patient safety implications.
• Supplies and facilities, particularly personal protective equipment (PPE).
• Patient access with an increased emphasis on communication and education for patients, staff, and providers; includes a plan for patient redirection and triage.
• Non-provider staffing related to both support levels (capacity/volume) and operational efficiency (e.g., assignment of roles and responsibilities, workflow redesign, etc.).
• Technology utilization, including telehealth services, EHR visit templates, and patient portals.
• Revenue cycle impact, including reimbursement, coding, fee schedule management.
• The overall financial impact for both revenue and expense management, adjusting near-term targets and expectations, as well as annual budgets.

If you have not previously developed a telemedicine strategy, you may not be behind the curve. However, if you do not have telemedicine capabilities now or as we emerge from the impact of COVID-19, you may fall behind this new standard of care delivery. Telemedicine may be having a moment nationally, which is a positive development and potentially overdue, but we believe the implications will endure for the long-term. We encourage you to maximize the long-standing benefit potential of your near-term efforts and responsiveness.Our consulting team is helping clients develop and implement rapid response plans to manage immediate priorities, and we also focus on operational sustainability. Whether you are focused on merely weathering the storm or using the pandemic as a catalyst to bolster your care delivery model and telehealth capabilities, we want to hear about your progress and where we can be helpful. Please let us know if you have questions, want to discuss your plan, share what we are learning, or strategize together to address these unprecedented challenges.The following list of additional resources is for your convenience.

Additional Resources

• Telemedicine Applications and General Information
• COVID-19 Resources for Medical Professionals (includes Communications and Telemedicine Resource Bundle)
• Telehealth Coding and Billing Practice Management Tips
• Coding Information for Coronavirus
• CPT Code for Reporting Covid-19 Test

Payer-Related Resources

• https://www.amga.org/performance-improvement/covid-19/payer-resources/
• https://www.ahip.org/health-insurance-providers-respond-to-coronavirus-covid-19/?mod=article_inline
• https://www.beckershospitalreview.com/telehealth/new-jersey-orders-all-state-health-insurers-to-reimburse-telehealth-visits-during-coronavirus-pandemic.html