Health and Human Services Secretary Alex Azar declared a public health emergency (PHE) on January 27, 2020. Subsequently, Congress passed and the president signed three bills that provide varying degrees of regulatory and financial relief for healthcare providers during the Coronavirus (COVID-19) PHE. These have triggered a cascade of actions from the Centers for Medicare and Medicaid Services (CMS) designed to increase access to and use of telehealth services, and provide flexibilities for providers to complete certain administrative requirements virtually. Greater reliance on virtual care and administration may limit patient travel and exposure to COVID-19 and reduce the spread of the virus, in adherence to other federal guidelines. At the same time, telehealth gives providers an opportunity to provide some healthcare services to their patients without a face-to-face encounter, preserving revenue during the crisis.
Key Takeaways
• Congress and the Administration have substantially loosened Medicare restrictions on, and expanded the use of, telehealth services, but only for the duration of the COVID-19 PHE.
• Congressional and CMS action has expanded reimbursable Medicare telemedicine services, changed the payment rate for certain telehealth services, and waived specific requirements and restrictions related to the use of telemedicine.
• Misunderstandings and confusion persist due to regulatory complexity and past messaging inconsistencies.
• States continue to individually evolve their licensing and reimbursement policies.
For more information, contact Rachel Stauffer, Mara McDermott, Sheila Madhani, Jessica Roth, Dale Van Demark, Lisa Schmitz Mazur, Marshall Jackson, Jr., or Amanda Enyeart.