2019 Priorities for South Carolina Telehealth Payers

Adopt Recent Medicare Coverage Changes

Bipartisan Budget Act of 2018

  • Expanding Access to Home Dialysis Therapy. This provision allows Medicare beneficiaries an option by which they may elect to receive in-home dialysis monthly as well as ESRD-related clinical assessments via telehealth services.
  • Increasing Convenience for Medicare Advantage Enrollees through Telehealth. This provision states that, beginning in plan year 2020, a new medial assistant plan may be able to provide additional telehealth benefits to Medicare enrollees.
  • Providing Accountable Care Organizations the Ability to Expand the Use of Telehealth. Accountable Care Organizations (ACOs) will now be able to waive restrictions on the use of telehealth from 1834(m) of the Social Security Act, which placed limits on how and under what conditions telehealth services could be used by beneficiaries.
  • Expanding the Use of Telehealth for Individuals with Stroke. Further expanding the use of Telestroke services, this provision waives 1834(m) restrictions on the treatment of stroke through telehealth services.

SUPPORT for Patients and Communities Act

"The Act amends 42 U.S.C. § 1395m(m) to eliminate these coverage restrictions for an eligible telehealth individual with a substance use disorder diagnosis for purposes of treatment of such disorder or co-occurring mental health disorder, as determined by the Secretary [of Health and Human Services].” -National Law Review

Other Recent Federal Changes

  • Remote Evaluation of Pre-Recorded Patient Information: Store and forward telehealth services (e.g. tele-dermatology) also known as remote evaluations of videos and/or images (“store and forward”), sent by the patient, have demonstrated enhanced access and effective delivery of clinical care. Medicare code: G2010
  • Brief Communication Technology-Based Service: Virtual check-ins allow providers (e.g. primary care, mental health) to efficiently use new technologies to deliver more cost-effective follow-up care for their patients. Medicare code: G2012
  • Remote Patient Monitoring ("RPM"): RPM coverage provides a separate payment for time spent on collection and interpretation of health data (e.g. blood pressure, glucose) to support population health and care coordination services. Medicare codes: 99453, 99454, 99457
  • Interprofessional Internet Consultations: Provider-to-provider consultations (“e-consults”) provide more efficient access to specialty care and have been shown to reduce unnecessary referrals by up to 40%. Medicare codes: 99446, 99447, 99448, 99449, 99451, 99452

Additional Provider Types

To improve cost-effective health care access, the SCTA urges SC Medicaid and SC PEBA to expand their list of covered telehealth providers beyond physicians and advanced practice providers to also include the below licensed providers:

  • Clinical Psychologists
  • Master’s degree level mental health providers (example: LISW-CP)
  • Registered dieticians
  • Respiratory therapists

Additional Patient Locations

Remove Originating Site Restrictions: The SCTA urges SC PEBA to remove originating site restrictions to allow providers to reach patients using telehealth in more cost-effective care settings (e.g. home, schools, skilled nursing facilities).

Originating Site Facility Fee: To prevent a financial disincentive for using telehealth within primary care settings, the SCTA urges SC Medicaid to provide a facility fee payment amount that is comparable to the current Medicare rate. COMPLETE!

For Future Exploration

Behavioral Health Integration (BHI): The SCTA will be exploring the use of BHI delivered using telehealth technology to support Project ECHO and similar models to be deemed billable collaborative time and allow for required availability of the behavioral manager to be enabled via telehealth. Medicare codes: 99484, 99492, 99493 and 99494

Medicare Payer Priority

Medicare Rurality Restrictions: Understanding there are many barriers to care in addition to a patient’s location, the SCTA urges Medicare to remove geographical restrictions based on rurality.