As the nation comes to terms with the possibility of widespread COVID-19 infections, announcements about new guidelines and regulation changes are being made daily. 第一个 COVID-19救济法案(H.R. 6074),并于3月6日由特朗普总统签署 在这里 通过心电图, expanded access to telehealth services for Medicare beneficiaries, reduced restrictions related to the originating site of care, and provided the ability to receive a telehealth screening via smartphone. On March 17, the president and CMS announced additional clarification and guidance for H.R. 6074 that will be critical for providers interested in using telehealth to screen for and treat COVID-19.
扩展远程医疗与1135豁免
One noteworthy limitation of the March 6 legislation was that in order for a Medicare beneficiary to receive telehealth services, they were required to have an established relationship with the provider. The patient also needed to have received a Medicare-covered service within the last three years from the provider or another provider in the same practice. CMS现在已经宣布 audits will not be conducted to ensure a prior relationship existed,从而消除了接受护理的潜在障碍.
Under the new CMS guidelines and as a tactic to reduce the risk of exposure to COVID-19, Medicare beneficiaries can now also receive an expanded list of services via telehealth, 包括E&M visits, behavioral health, and preventive health screenings. All telehealth visits will be reimbursed at the same rate as in-person visits.
While these new telehealth benefits apply to traditional Medicare, 医疗保险优势计划继续跟进 CMS上周发布的指南. These guidelines provide increased flexibilities in regard to waiving cost sharing of COVID-19 treatment, 包括远程医疗, 扩大远程医疗bet8娱乐. While opportunities exist to offer additional telehealth services, payers continue to have discretion in their service offerings. 因此, providers should work closely with Medicare Advantage plans to clarify and confirm that they will follow these new CMS guidelines.
虚拟业务类型
The March 17 CMS guidance identified and differentiated three types of COVID-19 virtual services that clinicians can provide to Medicare beneficiaries under the new 1135 waiver, 不论受益地域.
远程医疗访问: Providers can use an interactive audio/video telecommunications system that permits real-time patient communication for office visits, 医院, and other services that would otherwise generally occur as an in-person encounter. 重要的是, while CMS notes the previous requirement that Medicare beneficiaries have a prior established relationship with eligible providers, CMS explicitly states that HHS will not conduct any audits to ensure that the required prior relationship existed for any claims submitted during this public health emergency. CMS提供的完整列表 101个可通过远程医疗提供的代码 网上参考.
虚拟签到: A brief patient interaction with a clinician can occur via a number of communication modalities, including synchronous discussion over a telephone or exchange of information through video or image. This method of service is meant for patients with an established relationship with the provider, and w在这里 the communication is not related to a medical visit within the previous seven days and does not lead to a medical visit within the next 24 hours. Existing Medicare coinsurance and deductibles would apply, and patients must verbally consent to receive a virtual check-in.
E-Visits: Non–face-to-face patient-initiated communications or online evaluation and management with an eligible clinician can occur via the use of an online patient portal over a seven-day 期. 类似于虚拟签到, patients must have a previously established relationship with the provider and have initiated the virtual inquiry.
For more information and additional specifics of these telehealth rule changes, please see CMS实况介绍.
违反HIPAA的例外
In an unprecedented move that highlights the gravity of the COVID-19 situation, HHS has agreed to “exercise discretion and waive penalties” for any HIPAA violations committed by healthcare providers who “serve patients in good faith through everyday communication technologies such as FaceTime or Skype” during the recognized national emergency time 期.
期待
While these new federal guidelines can greatly expand providers’ ability to appropriately screen and treat patients through telehealth, 有必要指出这一点 各州的具体规定仍然有效 复杂性将继续被发现.
此外,H.R. 6074 was the first of at least three large emergency COVID-19 legislative actions meant to help stimulate the American economy and provide support for COVID-19 screening and treatment. At least two more bills are also expected to pass through Congress for President Trump to sign in the coming days that will likely have additional implications for telehealth screening and treatment, including potential reimbursement guidance for commercially insured or uninsured patients. We expect to see continued updates related to telehealth services as a result of changes occurring on a state level, 附加CMS指南, 新的联邦立法.
2020年3月18日发布