Last month, a federal bill was introduced and passed by the Senate that enables Medicare Advantage (MA) plans to reimburse for telehealth services at comparable rates to in-person services beginning in 2020. Currently, MA plans offer telehealth coverage for an additional premium; a supplemental benefit. The new bill requires Medicare Advantage plans to reimburse for telehealth services at the same rate as Medicare fee-for-service.
While the adoption of this bill continues to expand the ability of providers to reach patients through telehealth, the Centers for Medicare and Medicaid Services (CMS) imposes many limitations on both patients and providers in order to engage in a reimbursable encounter. It is the intent of the new bill to be a “parity” of Medicare fee-for-service. Therefore, providers can anticipate that service provided to beneficiaries of MA plans will be subject to similar limitations.
Telemedicine continues to expand pursuant to favorable reimbursement guidelines and support from both federal and state legislatures. However, providers must stay apprised of relevant guidelines for payment to ensure their encounters are properly performed and documented. For example, CMS reimbursement guidelines require patients to be located in certain designated sites in order to conduct a valid encounter.
In addition to stringent CMS billing requirements, state laws vary with respect to permissible telehealth encounters. Providers must be cognizant of applicable state medical board regulations, which may permit or impede the provider’s ability to develop a physician-patient relationship with an individual through telemedicine.
Failure to adhere to the requirements of both federal and state law, as well as reimbursement guidelines, may result in investigations or audits by applicable licensing boards and payors. If you or your practice intend to incorporate telemedicine into the scope of services provided to patients, contact Frier Levitt for assistance in developing a business model that maintains compliance with applicable law and ensures patient encounters are performed to meet reimbursement requirements.