Although the federal government has extended the telehealth waivers for another two years, the current rate of reimbursement, which is higher, will be in place only by the end of this year.
At the time of public health emergency, the centres for Medicare and Medicaid services gives back to the providers at the non-facility rate which develops a payment parity both among the in-person as well as a telehealth visit.
Originally, the telehealth flexibilities received an extension for 151 days and thereafter a 2-year addition after the end of the public health emergency. If, as projected, the public health emergency concludes in mid-April, other providers as well as the health systems can anticipate waivers on telehealth to continue by the end of 2024.
Although the current reimbursements shall last only till 2023 as per American Telemedicine Associations senior vice president for public policy, Kyle Zebley. Post which the rates could re-enter the pre-pandemic levels that were lower. It is anticipated that more about this will be known once the annual physician fee schedule is released by CMS.
Based on the physician fee schedule, there is a good chance it will go down next year, as per Zebley.
When the COVID-19 lockdown was at its peak, many of the health systems as well as hospitals relied upon telehealth. The investments were already made by executives in infra and technology for telehealth as the number of individuals using online care surged. One of the big hurdles as far as its use is the question related to payment parity.
Many regulatory as well as legislative hurdles were taken care of by the recently-passed omnibus bill; however, there was a silence on the reimbursement issue, according to Zebley.
There has been a dearth of legislative action on this issue since the authority to take care of the reimbursement happens through CMS authority. The biggest change, as per Zebley, that has occurred across the pandemic for CMS is a higher reimbursement interest rate.
The payment decision is made by the CMS during the annual physician fee schedule. The providers will be able to get the notice around July 4, as the draft proposal with regard to rates and other policies is released by the agency. There will then be a period of 90 days which the stakeholders shall get to respond before the CMS gets on with its final rule which will be up and running from January 1, 2024.
Apparently, Medicare has already added more than 100 billing codes for the duration of the public health emergency. As of now, the telehealth visits that are billed to Medicare are paid on the basis of a fee-for-service rate just like an in-person visit.
It is well to note that the payment parity is based on the facility rates. Before the pandemic, there was limited reimbursement for telehealth, such as when the person getting the service happened to be in a designated rural area and also when the person left home to go to the clinic, medical facility, or any other hospital to get the service.
Throughout the pandemic, the CMS put forth high reimbursements at non-facilities like from home of the patient. Zebley confirms that CMS will continue to go ahead with the higher rate of medical reimbursement this year.
The commercial insurers happen to be regulated by state law. Zebley says that half of the states have already passed parity laws on payments. In the next half, the commercial plans happen to vary pretty widely as to what will be covered and the rate at which the reimbursement will be done. This is going to be the same for the same insurers across states.
As per Zebley, even major players shall vary largely from one state to another. CMS has already removed restrictions on Medicare for providing services across state lines; however, that doesn’t negate the state law. As and when CMS decides on reimbursements after 2023, telehealth will be there. There is immense positive momentum as the providers look forward to delivering it and the patients want to continue having it.
During 2020, there was a heightened telehealth use in the medical settings and it still happens to be 65% higher than what the numbers were before 2020.
That said, the utilisation of telehealth has dipped by almost 4% as per the October 2022 figures according to FAIR Health’s monthly regional telehealth tracker.
The question of reimbursement is critical, and as per Zebley, there are still central and state impediments that need to be worked out. The ATA is pushing for a continued rate of non-facility reimbursement and is also supporting flexibility between the providers of services as well as the payers.
