ACC Health Law Committee Webcast. Telemedicine and TeleHealth: Who s Doing What; What You Should Know. Alan Einhorn, Esq. Foley & Lardner, LLP
|
|
- Candace Richard
- 5 years ago
- Views:
Transcription
1 ACC Health Law Committee Webcast Telemedicine and TeleHealth: Who s Doing What; What You Should Know. Alan Einhorn, Esq. Foley & Lardner, LLP Keith L. Henderson, Esq. Chief Compliance Officer Morehouse School of Medicine May 9, 2018
2 Telemedicine Overview What is Telehealth & Telemedicine Telehealth Reimbursement Telehealth Business Models Legal Considerations
3 What is Telehealth? A collec'on of means or methods for enhancing health care, public health, and health educa'on delivery and support using telecommunica'ons technologies
4 State vs Federal Defini4ons Federal Law Health Resources and Services Administra5on (HRSA) defines telehealth as: The use of electronic informa'on and telecommunica'ons technologies to support long-distance clinical health care, pa'ent and professional healthrelated educa'on, public health and health administra'on. California law defines telehealth as: The mode of delivering health care services and public health via informa'on and communica'on technologies to facilitate the diagnosis, consulta'on, treatment, educa'on, care management, and self-management of a pa'ent's health care while the pa'ent is at the origina'ng site and the health care provider is at a distant site. Telehealth facilitates pa'ent selfmanagement and caregiver support for pa'ents and includes synchronous interac'ons and asynchronous store and forward transfers.
5 Challenges to Implemen4ng Telemedicine Source: 2017 Telemedicine and Digital Health Survey Foley & Larder, LLP
6 Modali4es of Telehealth Real-'me Live Video Synchronous Remote Pa'ent Monitoring Modali'es mhealth Store and Forward Asynchronous
7 Trends in Modali4es Real-Time Video - 48 states and District of Columbia allow for Medicaid reimbursement Asynchronous Store-and-Forward 15 states allow for Medicaid reimbursement Remote Pa:ent Monitoring 21 states allow for Medicaid reimbursement 9 states allow for Real-Time Video, Store and Forward, and Remote Pa:ent Monitoring (AK, AZ, IL,MN,MI,MO,OK,VA & WA)
8 Medicaid Reimbursement Requirements Under Medicaid states implementa'on of Telemedicine varies by state. Providers must meet federal requirements under the federal law but also understand the specific state law provisions that govern Telehealth/Telemedicine 8
9 Medicaid Reimbursement Factors Telemedicine qualifying reimbursement considera'ons under Medicaid: Health Services covered Eligible providers (NPs, PAs) Is cross-state medical licensing allowed? Is a pre-exis'ng rela'onship with pa'ent required? Loca'on restric'ons on pa'ent or provider Applicable CPT codes Type of fee reimbursed (transmission, facility, or both)
10 State Telehealth Laws - Medicaid Source: Center for Connected Health Policy (2017)
11 Medicare Telehealth Reimbursement Reqs. Defining the Origina4ng and Distant Sites. Medicare reimburses for telehealth services offered by a healthcare provider at a distant site, to a Medicare beneficiary (the pa'ent) at an Origina'ng Site. The origina'ng site must be in a HPSA (Health Professional Shortage Area). In order to be eligible for Medicare reimbursement, the pa'ent (Medicare beneficiary) needs to be receiving virtual care at 1 of 8 clinical seengs, namely: Physicians or prac''oner offices Hospitals Cri'cal Access Hospitals (CAH) Rural Health Clinics Federally Qualified Health Centers Hospital-based or CAH-based Renal Dialysis Centers (Not Independent Renal Dialysis Facili5es) Skilled Nursing Facili'es (SNF) Community Mental Health Centers (CMHC).
12 Medicare Telehealth Reimbursement Reqs. Facility Fees. In addi'on to reimbursement for the telemedicine service, Medicare will pay the origina'ng site a facility fee. For example, if you re a primary care provider with a pa'ent in your office and you do a telemedicine visit to consult a physician in another loca'on, you could bill for two separate things the telemedicine service, and a facility fee for using your prac'ce to host of the pa'ent visit. Eligible Providers. Under Medicare, the following healthcare providers can use telemedicine: Physicians Nurse Prac''oners Physician Assistants Nurse Midwives Clinical nurse specialists Clinical Psychologists Clinical Social Workers Registered die''ans or nutri'on professionals 12
13 Medicare Telehealth Reimbursement Reqs. Modality Provider must use an interac've audio and video system that ensures real-'me live communica'on with provider, the distant site and the beneficiary. CPT/HCPCS. (Current Procedural Terminology/ Healthcare Common Procedure Coding Systems) is listed as a covered telehealth service. 13
14 Top Telemedicine Special4es A few of the most popular telemedicine special'es are: Radiology offer providers at one loca'on to send a pa'ent s x-rays and records securely to a qualified radiologist at another loca'on, and get a quick consult on the pa'ent s condi'on. Psychiatry allows qualified psychiatrists to provide treatment to pa'ents remotely, expanding access to behavioral health services. Dermatology solu'on are usually store-and-forward technologies that allow a general healthcare provider to send a pa'ent photo of a rash, a mole, or another skin anomaly, for remote diagnosis. As frontline providers of care, primary care prac''oners are oken the first medical professionals to spot a poten'al problem. It allows PCPs con'nue to coordinate a pa'ent s care, and offer a quick answer on whether further examina'on is needed from a dermatologist. Ophthalmology solu'ons allow ophthalmologists to examine pa'ents eyes, or check-in about treatments from a distance. A common example is an ophthalmologist diagnosing and trea'ng an eye infec'on. These solu'ons are usually either live or store-and-forward telemedicine. Nephrology solu'ons are most commonly used interprofessionally, when a family physician needs to consult a nephrologist about a pa'ent with kidney disease. Obstetrics allow obstetricians to provide prenatal care from afar. This could mean, for example, recording a baby s heart at one loca'on and forwarding it to an obstetrician for diagnosis at another facility. Oncology provide more accessible and convenient care to pa'ents with cancer. Some solu'ons offer storeand-forward tools to forward images for diagnosis, others are live video plalorms to allow pa'ent consults with the oncologist. Pathology pathologists share pathology at a distance for diagnosis, research, and educa'on. Most telemedicine tools in this area are store-and-forward solu'ons, allowing pathologists to share and forward high-resolu'on images and videos. Rehabilita:on allow medical professionals to deliver rehab services (such as physical therapy) remotely.
15 Common Condi4ons Treated Allergies Arthri'c Pain Asthma Bronchi's Diabetes Hypertension Behavioral Health/ Mental Illness Insect Bites Sinusi's Conjunc'vi's Skin Inflamma'ons Celluli's Sore Throats Rashes Bladder Infec'ons UTIs Sprains & Strains 15
16 Restric4ons on Services Medicare reimburses generally for very specific health services provided via telemedicine, oken with strict requirements. Although, Medicare has expanded the list of reimbursable telemedicine services it s'll imposes many restric'ons on how the service is provided in order to be covered.
17 Revenue Cycle - Billing Only certain CPT and HCPCS codes are eligible for telemedicine reimbursement. Medicare has a specific list of CPT and HCPCS codes that are covered under telemedicine services. Be sure to check the CMS website for the most up-to-date codes. When billing, use the Place of Service POS 02 modifier. When billing for telemedicine visits, you need to include the POS O2 modifier with the relevant CPT code to indicate the service was provided virtually, except in Alaska and Hawaii where the GT or GQ modifier is required.
18 Private Payers Private payers con'nue to grow in allowing for reimbursement of some telehealth services but they are not consistent across payers as to what is covered and there are no federal requirements to provide coverage for telehealth services 36 states and DC have laws that affect telehealth reimbursement by private payer plans. (2017)
19 OIG Medicare Telehealth Project Health and Human Services, Office of the Inspector General (OIG), audit uncovered 31% of a sample claims did not meet Medicare reimbursement requirements. Audit revealed that 191,118 Medicare claims totaling $13.8 million did not have origina'ng site claims.
20 OIG Medicare Telehealth Project OIG will be reviewing Medicare claims paid for telehealth services provided at distant sites that do not have corresponding claims from origina'ng sites to determine whether those services met Medicare requirements. OIG will also determine whether states Medicaid payments for services delivered via telehealth were allowable. Telehealth services must have been delivered through a range of interac've video, audio or data transmissions. 20
21 New Telehealth Law Changes Bipar4san Budget Act of 2018 Key changes to the law under Medicare for telehealth include: (1) expanding stroke telemedicine coverage; (2019) (2) improving access to telehealth-enabled home dialysis oversight; (2019) (3) enabling pa'ents to be provided with free at-home telehealth dialysis technology without the provider viola'ng the Civil Monetary Penal'es Law; (2019) (4) allowing Medicare Advantage (MA) plans to include delivery of telehealth services in a plan s basic benefits; (2020) and (5) giving Accountable Care Organiza'ons (ACOs) the ability to expand the use of telehealth services to include pa'ent homes as an origina'ng site and eliminates rural restric'ons. (2020)
22 New Telehealth Law Expansion Cont d Medicare Advantage Plans are allowed to include Telehealth Services as a Basic Benefit Medicare Advantage plans will be allowed to offer addi'onal, clinically appropriate telehealth benefits in their annual bid amounts beyond the services that currently receive payment under Medicare Part B. The law provides MA plans the ability to offer telehealth services as part of their basic benefit package (i.e., as if the telehealth services were benefits under the original Medicare fee-for-service program op'on). The type of telemedicine service that qualifies as a basic benefit is s'll being defined with a comment period through November 18, 2018.
23 Reimbursement for Telemedicine Source: 2017 Telemedicine and Digital Health Survey Foley & Larder, LLP
24 OFFICE OF COMPLIANCE & CORPORATE INTEGRITY Keith L. Henderson, JD, LL.M. Chief Compliance Officer Morehouse School of Medicine Atlanta, Georgia May 9, 2018
25 Telemedicine Business Models 25
26 Institution to Institution One institution (and its providers) provides clinical care/assistance to the patients (or providers) of another institution E.g. Hospital to hospital specialty services consults and/or direct patient care Telestroke and E-ICU services Weekend and/or weeknight rounds Urgent care center services (including physician availability, oversight of advanced practice providers) Post-discharge services, including follow-up monitoring 26
27 Institution to Institution (cont d) Also includes, e.g., Acute hospital agreements with SNF s Psychiatric facilities Clinics and other ambulatory care providers For Consults Back-up coverage Patient care services 27
28 Institution to Institution (cont d) Components of Institution to Institution Arrangements Professional Services Agreement Services to be provided, including supervision requirements (as applicable) Fee/payment arrangements Duration and termination Credentialing Agreement (if Credentialing by Proxy) Technology and support Agreement Technology to be Provided or Utilized Responsibility for Integration Responsibility for maintenance and upgrades Fee/payment arrangements 28
29 Non-Institution Provider to Institution Provider or Provider Practice provides clinical and/or consult services to Institutional Provider and/or that Provider s patients E.g., Distant site telemedicine entity to hospital/hospital service line Teleradiology, teleneurology, telepsychiatry, other Distant site telemedicine entity, physician/provider practice, or provider to skilled nursing facilities, clinics, urgent care centers on a consulting or patient care basis Components of Non-Institution Provider to Institution arrangements Similar to institution to institution arrangements, particularly if the institution is a hospital 29
30 Clinician to Clinician Typically, a generalist to specialist arrangement, for specialty consultation services and/or clinical services to patients. E.g., Telepsych Neurology Cardiology Dermatology Ocular medicine Components of Clinician to Clinician Arrangements Professional Services Agreement Technology and support Agreement 30
31 Direct to Patient Enables patients to obtain direct access to care-givers for consultation, monitoring of condition and/or care plan compliance, referral, etc. May include: Online second opinion services Patient navigation/care management Chronic Care Management (Medicare service available to patients with qualifying conditions in practices that satisfy certain status review and communication requirements) Components of Direct to Patient Arrangements Primarily a physician/patient relationship consistent with applicable regulatory requirements, and insurance coverage (or a payment arrangement for non-covered services) 31
32 Other Arrangements The following services/arrangements are frequently components of the foregoing business models: Monitoring- processes/technologies that are intended to enhance the service offerings of the distant site telemedicine provider and offer more comprehensive clinical services to the patient and/or originating site, e.g., monitoring ICU beds and enabling distant site clinicians to serve as care quarterback to direct care or consult with on-site staff. Monitoring chronic care patients vital signs and/or care plan compliance to facilitate ongoing care management Improves quality, creates cost-savings, reduces admissions/readmissions. 32
33 Other Arrangements (cont d) Hardware/Software-to facilitate the delivery of services remotely E.g., kiosks, workstations Allows delivery of direct services where on-demand care is desired or needed Can include -factories -other work sites (even oil rigs) -schools Also allows incorporation of audio-video and asynchronous modalities (e.g., diagnostic peripherals). For work-sites, promotes stay at work opportunities, less time off for, e.g., unnecessary travel, wait time. 33
34 Legal Considerations 34
35 Telemedicine and Licensing Physician offering care via telemedicine is subject to licensure rules of the state in which the patient is physically located at the time of the consult. State law expressly or implicitly requires licensure if the patient is located in the state at the time of the consult. 35
36 Telemedicine and Licensing (cont d) Understanding the licensing laws/regulations of the state(s) in which the physician is practicing is critical, because some states: allow unlicensed physicians to perform peer to peer consultations with physicians who are licensed in those states; allow out-of-state physicians who are licensed in border states to practice without a license in the state; have abbreviated license options or registrations for in-state telemedicine only care; allow physicians to provide follow-up care to their own patients (e.g., post-op, or travel) Also, some states have joined or are considering joining the Federation of State Medical Boards Interstate Medical Licensure Compact 36
37 Telemedicine and Licensing (cont d)- Practice Standards Practicing in a state also means adherence to that state s medical practice standards. Apart from the above, one should ask: Can a valid physician-patient relationship be established in the state via telemedicine without an in-person exam? What ARE the minimum requirements for establishing a physicianpatient relationship What modality of telemedicine is required to establish a valid physician-patient relationship? None may be stated. The gold standard is audio-video while the physician has the patient s medical record available. 37
38 Telemedicine and Licensing (cont d)- Practice Standards What modality is required/allowed for ongoing telemedicine practice purposes? Does the state impose any originating site restrictions for telemedicine practice purposes? Does the state require a patient-site tele-presenter? Does the state allow telemedicine prescribing of noncontrolled substances without a prior in-person exam? Does the state allow telemedicine prescribing of controlled substances without a prior in-person exam? And are there ongoing visit requirements when prescribing particular schedules of controlled substances? 38
39 Telemedicine and Licensing (cont d)- Practice Standards Are there special medical records guidance/ requirements? Are there state telemedicine consent requirements? Note that some states do have these requirements even though telemedicine is not a medical specialty, is not inherently dangerous, and is not generally associated with unusual risks. 39
40 AKS, Stark, CMP and State Analogs Any time a provider enters into an arrangement with an individual or entity that has the potential to refer, or influence referrals to that provider for clinical services or other business, the provider (and the other party to the transaction) must consider, and address if necessary, a host of federal and state laws, particularly if the services or business that may referred is paid for by Medicare or Medicaid. This includes, e.g.: Institution to institution or institution to provider arrangements, Clinician to clinician arrangements, and even Direct to consumer arrangements 40
41 AKS, Stark, CMP and State Analogs (cont d) Federal Laws Anti-Kickback Statute Physician Self- Referral Civil Monetary Penalty Law State Laws Patient Brokering Acts Self-Referral Laws
42 AKS, Stark, CMP and State Analogs (cont d) Avoidance of the penalties associated with these laws requires compliance with applicable regulatory safe harbors or exceptions, including, generally: Memorializing the arrangements with written agreements Describing the specific services to be provided, including timeframes Paying fair market value compensation Paying compensation that does not vary based on the volume or value of referrals or other business 42
43 Corporate Practice and Fee Splitting Entities that are not owned or controlled solely by practitioners or their clinical practice entities are prohibited from providing medical/clinical services in some states. This prohibition is referred to as the corporate practice of medicine. It applies to businesses that employ physicians and other providers to provide clinical services, but can also apply to hospitals that employ providers and seek to have those providers provide services in states where the hospitals are not licensed. A friendly PC model is often utilized as a solution to corporate practice prohibitions 43
44 Corporate Practice and Fee Splitting (cont d) Non-Physician Owner(s) Physician Owner(s) MSO PC Contracted / Employed Professionals
45 Corporate Practice and Fee Splitting (cont d) State Fee-Splitting Statutes preclude physicians/other practitioners from splitting their earnings from professional services with others who did not play a bona fide role in the delivery of the services. Fee splitting statutes can implicate business arrangements where it appears that, e.g., A provider is being compensated for something other than clinical or related administrative services (e.g., referrals) A manager is receiving a disproportionate payment for services or purported services 45
46 Credentialing Providers of service should seek to ensure that those providing clinical services to their patients including distant site telemedicine providers are qualified to provide those clinical services Credentialing standards are most clearly articulated for hospitals, as a result of explicit CMS COPS, state licensure and accreditation requirements. A hospital that utilizes distant site telemedicine services must credential the distant site providers one-by-one, unless it (i) has Medical Staff Bylaws in place that accommodate credentialing by proxy, a process that allows the hospital to rely, in large part, on the credentialing performed by either a distant site hospital or distant site telemedicine entity, and (ii) has a credentialing agreement with the distant site entity that satisfies both COPS and accreditation standards, and is consistent with state law. 46
47 HIPAA, Security Those providing telemedicine services must comply with applicable federal and state laws relating to privacy and security. This is, in effect, no different than what is required in other clinical situations except that telemedicine services necessarily require the transmission of protected health information between and among sites, thereby arguably elevating associated risks. 47
48 Liability Here, too, the risks associated with telemedicine services are not unlike those faced by other providers. Risks include, but are not limited to Malpractice/negligence in connection with the delivery of services Breach of contract Billing and coding related errors and/or billing fraud or misfeasance Privacy and/or security breaches Additional liability considerations associated with the delivery of telemedicine services may include: -choice of modality/technology -failure to properly obtain or maintain modality/technology -use of practitioners/personnel to deliver services who are unfamiliar to the distant site provider, or not adequately trained on the technology, or not properly supervised (by the distant site provider, and/or the originating site) 48
49 Questions? Alan Einhorn, Esq. Of Counsel Foley & Lardner LLP Co-Chair, Compliance and Operations Work Group One Law Firm. All Your Digital Health Needs. Telemedicine Telehealth Virtual Care mhealth Fraud and Abuse Regulatory Compliance International/Destination Medicine Reimbursement and Payment Contracting and Joint Ventures M&A Licensure and Practice Concierge Medicine Privacy and Security 49
50 Thank you ATTORNEY ADVERTISEMENT. The contents of this document, current at the date of publication, are for reference purposes only and do not constitute legal advice. Where previous cases are included, prior results do not guarantee a similar outcome. Images of people may not be Foley personnel Foley & Lardner LLP
19/09/2017. Telehealth Legal and Regulatory Issues in Colorado and Beyond. Nathaniel Lacktman, October 2017
Telehealth Legal and Regulatory Issues in Colorado and Beyond Nathaniel Lacktman, Esq. @Lacktman October 2017 1 2 1 Licensing 3 Licensing Physician offering care via telemedicine is subject to licensure
More informationTelehealth Legal and Compliance Issues. Nathaniel Lacktman, Anna Whites, Esq.
Telehealth Legal and Compliance Issues Nathaniel Lacktman, Esq. @Lacktman Anna Whites, Esq. Anna Whites Law Office Attorney Advertising Prior results do not guarantee a similar outcome Models used are
More informationTelemedicine and Reimbursement
Telemedicine and Reimbursement Presented for : March 14 th 2018 About Acevedo Consulting Incorporated Acevedo Consulting Incorporated prides itself on not providing cookie-cutter programs, but a quality
More informationTelemedicine Guidance
Telemedicine Guidance GEORGIA DEPARTMENT OF COMMUNITY HEALTH DIVISION OF MEDICAID Revised: October 1, 2017 Policy Revisions Record Telemedicine Guidance 2017 REVISION DATE Oct. 1, 2017 SECTION REVISION
More informationWhat is Telemedicine and How is It Being Used?
What is Telemedicine and How is It Being Used? March 14, 2018 Presented by: Attorney Karina P. Gonzalez Florida Healthcare Law Firm www.floridahealthcarelawfirm.com 2016 The Law Offices of Jeff Cohen,
More informationTelehealth 101. Telehealth Summit May 24, 2018
Telehealth 101 Telehealth Summit May 24, 2018 Tim Bickel Telehealth Director, University of Louisville Deborah Burton, Telehealth Program Manager, KentuckyOne Health, Lexington; Chair, Kentucky Teleheath
More informationProject: Telemedicine Engaging Your Providers in Your Telehealth Development and Program
Project: Engaging Your Providers in Your Telehealth Development and Program Presented by: James Dunnick, MD, FACC, CHCQM, CPC, CMDP - The Dunnick Group, LLC Learning Outcome Standard: This program is based
More informationCheryl A Skiffington, CCO & Interim CFO Columbia County Health System
Cheryl A Skiffington, CCO & Interim CFO Columbia County Health System Telemedicine is A mode of delivery The service provided is basically the same as if the patient and provider were face-to-face. A modifier
More informationTelemedicine and Fair Market Value What You Need to Know
Telemedicine and Fair Market Value What You Need to Know By Chris W. David, CPA/ABV, ASA August, 2017 Telemedicine (also known as telehealth) is a rapidly-evolving trend in the healthcare delivery space
More informationTHE TELEMEDICINE MARKET LANDSCAPE
How Telehealth is Changing the Care Provided to Patients Anne Cadwell, The Permanente Medical Group THE TELEMEDICINE MARKET LANDSCAPE Approximately 1 million virtual doctor visits in the U.S. in 2015 1
More informationLegal Issues You Should Know April 25, 2018 In-House Counsel Conference
1 TELEMEDICINE Legal Issues You Should Know April 25, 2018 In-House Counsel Conference Disclaimer: These materials and presentation are intended to be a general and brief summary of the law. This is not
More informationKeeping Your Compliance Program in Pace with Rapidly Expanding TeleHealth Services
Keeping Your Compliance Program in Pace with Rapidly Expanding TeleHealth Services In April 1924, an imaginative cover for the magazine Radio News foreshadowed telemedicine in its depiction of a "radio
More information9/21/2017. Telemedicine vs. Telehealth. Telemedicine vs. Telehealth. Telemedicine vs. Telehealth. Time is Money. Disruptive Technology
Telemedicine vs. Telehealth Telemedicine is the use of medical information exchanged from one site to another via electronic communications to improve patients health status. Telemedicine The Virtual Experience
More informationTelemedicine. Important Information. Telemedicine 5/6/2016. Lauren Prew
Telemedicine Lauren Prew Important Information This presentation is similar to any other seminar designed to provide general information on pertinent legal topics. The statements made and any materials
More informationu Telemedicine The Virtual Experience
Telemedicine The Virtual Experience April 2017 Telemedicine vs. Telehealth Telemedicine is the use of medical information exchanged from one site to another via electronic communications to improve patients
More informationTelemedicine Credentialing and Privileging
Presenting a live 90-minute webinar with interactive Q&A Telemedicine Credentialing and Privileging Protecting Patient Privacy, Avoiding Fraud and Abuse Liability, Ensuring Quality of Care THURSDAY, AUGUST
More information19 th Annual Western Regional Conference Women in Government May 21, 2016 Seattle, WA
TELE TODAY 19 th Annual Western Regional Conference Women in Government May 21, 2016 Seattle, WA 877 707 7172 cchpca.org Mei Wa Kwong, JD Senior Policy Associate & Project Director DISCLAIMERS Any information
More informationTelemedicine: The Basics And Answers to Ques6ons You Always Had But Never Asked
Telemedicine: The Basics And Answers to Ques6ons You Always Had But Never Asked Kelley Evans, Senior Counsel, Dignity Health Kelley.Evans@dignityhealth.org Associa6on of Corporate Counsel Health Law Sec6on
More informationTELEMEDICINE POLICY. Policy Number: ADMINISTRATIVE T0 Effective Date: January 1, 2018
TELEMEDICINE POLICY UnitedHealthcare Oxford Reimbursement Policy Policy Number: ADMINISTRATIVE 114.28 T0 Effective Date: January 1, 2018 Table of Contents Page INSTRUCTIONS FOR USE... 1 APPLICABLE LINES
More informationMedicaid Program Administrator: Bureau for Medical Services, under the West Virginia Dept. of Health and Human Resources
West Virginia Medicaid Program: West Virginia Medicaid Medicaid Program Administrator: Bureau for Medical Services, under the West Virginia Dept. of Health and Human Resources Regional Telehealth Resource
More informationTelehealth. Clinical Applications 6/28/2011 TELEHEALTH UPDATE: MONTANA AND BEYOND
TELEHEALTH UPDATE: MONTANA AND BEYOND Telehealth Telehealth is the delivery of healthrelated services via telecommunications technologies Clinical Applications Allergy Cardiology * Dermatology Oncology
More informationTelehealth and Children With Special Health Care Needs. Improving Access to Care and Care Coordination
Telehealth and Children With Special Health Care Needs Improving Access to Care and Care Coordination Jacob Vigil, MSW Program Associate The Children s Partnership Mei Wa Kwong, JD Senior Policy Associate
More informationTelehealth and Telemedicine Policy
Reimbursement Policy CMS 1500 Telehealth and Telemedicine Policy Policy Number 2018R0046B Annual Approval Date 7/12/2017 Approved By Reimbursement Policy Oversight Committee IMPORTANT NOTE ABOUT THIS REIMBURSEMENT
More informationWHITE PAPER #2: CASE STUDY ON FRONTIER TELEHEALTH
WHITE PAPER #2: CASE STUDY ON FRONTIER TELEHEALTH I. CURRENT LEGISLATION AND REGULATIONS Telehealth technology has the potential to improve access to a broader range of health care services in rural and
More informationTelehealth and Telemedicine Policy
Reimbursement Policy CMS 1500 Telehealth and Telemedicine Policy Policy Number 2018R0046J Annual Approval Date 7/11/2018 Approved By Reimbursement Policy Oversight Committee IMPORTANT NOTE ABOUT THIS REIMBURSEMENT
More informationI. LIVE INTERACTIVE TELEDERMATOLOGY
Position Statement on Teledermatology (Approved by the Board of Directors: February 22, 2002; Amended by the Board of Directors: May 22, 2004; November 9, 2013; August 9, 2014; May 16, 2015; March 7, 2016)
More informationTelehealth Reimbursement Policy in
Telehealth Reimbursement Policy in New York State Greater New York Hospital Association Telehealth Webinar Series July 11, 2016 July 2016 2 Agenda Telehealth NY State Telehealth Parity Statutory Changes
More informationChapter 7 Section 22.1
Medicine Chapter 7 Section 22.1 Issue Date: April 17, 2003 Authority: 32 CFR 199.4 and 32 CFR 199.14 Copyright: CPT only 2006 American Medical Association (or such other date of publication of CPT). All
More informationTelehealth and Telemedicine Policy
Telehealth and Telemedicine Policy Policy Number Annual Approval Date 7/11/2018 Approved By Oversight Committee IMPORTANT NOTE ABOUT THIS REIMBURSEMENT POLICY This policy is applicable to UnitedHealthcare
More informationTelemedicine Compliance Maximizing Patient Care & ROI While Minimizing Legal Risks
Live tweet - #telehealth2016 Telemedicine Compliance Maximizing Patient Care & ROI While Minimizing Legal Risks Mei Wa Kwong, JD Senior Policy Associate & Project Director Center for Connected Health Policy
More informationCruising Through Key Legal Compliance Issues in Telemedicine
April 12, 2018 Cruising Through Key Legal Compliance Issues in Telemedicine Presented by Cal Marshall 2018 Chambliss, Bahner & Stophel, P.C. All Rights Reserved. Chambliss, Bahner & Stophel, P.C. Liberty
More informationMISSOURI TELEHEALTH NETWORK TRAINING CONFERENCE January 31, 2018 CENTER FOR CONNECTED HEALTH POLICY POLICY DISCLAIMERS
LEGAL & REGULATORY ISSUES TO CONSIDER IN A TELE PROGRAM MISSOURI TELE NETWORK TRAINING CONFERENCE January 31, 2018 877-707-7172 cchpca.org Mei Wa Kwong, JD DISCLAIMERS Any information provided in today
More informationCorporate Reimbursement Policy Telehealth
Corporate Reimbursement Policy Telehealth File Name: Origination: Last Review Next Review: telehealth 11/1997 12/2017 12/2018 Description Telehealth is a potentially useful tool that, if employed appropriately,
More informationTELEHEALTH: THE FUTURE IS HERE!
TELEHEALTH: THE FUTURE IS HERE! OPPORTUNITIES FOR CAPTIVES, TRADITIONAL INSURERS AND RISK MANAGEMENT PROFESSIONALS Paul Greve, J.D., RPLU Executive Vice President Willlis Healthcare Practice Gary Leonard
More informationMEDICAL POLICY No R2 TELEMEDICINE
Summary of Changes Clarifications: Page 1, Section I. A 6, additional language added for clarification. Deletions: Additions Page 4, Section IV, Description, additional language added in regards to telemedicine.
More informationDIVISION OF HEALTHCARE FINANCING CMS 1500 ICD-10. October 1, 2017
DIVISION OF HEALTHCARE FINANCING CMS 1500 ICD-10 October 1, 2017 General Information Overview Thank you for your willingness to serve clients of the Medicaid Program and other medical assistance programs
More informationTelehealth and Telemedicine Policy Annual Approval Date
Policy Number Telehealth and Telemedicine Policy Annual Approval Date 04/12/2017 Approved By Oversight Committee IMPORTANT NOTE ABOUT THIS REIMBURSEMENT POLICY This policy is applicable to UnitedHealthcare
More informationTelehealth: Frequently Asked Questions
Telehealth: Frequently Asked Questions WHAT IS TELEHEALTH? Telehealth is the use of electronic information and telecommunications technology to support: THE DELIVERY OF HEALTH CARE PATIENT AND PROFESSIONAL
More informationRetail Clinics in Healthcare: Overcoming Complex Legal Challenges
Presenting a live 90-minute webinar with interactive Q&A Retail Clinics in Healthcare: Overcoming Complex Legal Challenges Complying With Corporate Practice of Medicine, Licensure, and Scope of Practice
More informationTelemedicine Policy Annual Approval Date
Policy Number 2017R0046A Telemedicine Policy Annual Approval Date 7/13/2016 Approved By REIMBURSEMENT POLICY CMS-1500 Payment Policy Oversight Committee IMPORTANT NOTE ABOUT THIS REIMBURSEMENT POLICY You
More informationH.R MEDICARE TELEHEALTH PARITY ACT OF 2017
FACT SHEET CENTER FOR CONNECTED HEALTH POLICY The Federally Designated National Telehealth Policy Resource Center Info@cchpca.org 877-707-7172 H.R. 2550 MEDICARE TELEHEALTH PARITY ACT OF 2017 SPONSORS:
More informationThe Telemedicine Opportunity. Presented By: Marybeth McCall, MD
The Telemedicine Opportunity Presented By: Marybeth McCall, MD 1962 Episode of the The Jetsons Presentation Objectives Identify telemedicine utilization projections Describe New York s Telemedicine Mandate
More informationTelemedicine and Telehealth Services
INDIANA HEALTH COVERAGE PROGRAMS PROVIDER REFERENCE M ODULE Telemedicine and Telehealth Services L I B R A R Y R E F E R E N C E N U M B E R : P R O M O D 0 0 0 4 8 P U B L I S H E D : J A N U A R Y 1
More informationMEDICAL POLICY No R1 TELEMEDICINE
Summary of Changes MEDICAL POLICY TELEMEDICINE Effective Date: March 1, 2016 Review Dates: 12/12, 12/13, 11/14, 11/15 Date Of Origin: December 12, 2012 Status: Current Clarifications: Deletions: Pg. 4,
More information5/1/2017. Medicare Coverage Guidelines for DSMT and MNT Telehealth. Telehealth Defined
Medicare Coverage Guidelines for DSMT and MNT Telehealth Mary Ann Hodorowicz, RDN, MBA, CDE Certified Endocrinology Coder Mary Ann Hodorowicz Consulting, LLC 4-30-17 MEDICARE DSMT - MNT TELEHEALH KEY TOPICS
More informationConflict of Interest Disclosure. Telemedicine: Credentialing And Best Practices. Learning Objectives. Learning Objectives. Telehealth.
Conflict of Interest Disclosure Telemedicine: Credentialing And s Catherine M. Ballard Partner Bricker & Eckler LLP 614-227-8806/cballard@bricker.com Use the following statement or disclose any relationships
More informationChapter 7 Section 22.1
TRICARE Policy Manual 6010.57-M, February 1, 2008 Medicine Chapter 7 Section 22.1 Issue Date: April 17, 2003 Authority: 32 CFR 199.4 and 32 CFR 199.14 1.0 DESCRIPTION 1.1 refers to the use of information
More informationTELECOMMUNICATION SERVICES CSHCN SERVICES PROGRAM PROVIDER MANUAL
TELECOMMUNICATION SERVICES CSHCN SERVICES PROGRAM PROVIDER MANUAL NOVEMBER 2017 CSHCN PROVIDER PROCEDURES MANUAL NOVEMBER 2017 TELECOMMUNICATION SERVICES Table of Contents 38.1 Enrollment......................................................................
More informationTRANSFORMING HEALTH CARE WITH CONNECTED HEALTH TECHNOLOGY
TRANSFORMING CARE WITH CONNECTED TECHNOLOGY TELE STATE TRENDS Florida Telehealth Advisory Council April 21, 2017 877-707-7172 cchpca.org Mario Gutierrez We are part of the Public Health Institute, an independent,
More informationTelemedicine Policy. 7/12/2017 Approved By
Telemedicine Policy Policy Number 2018R0046A Annual Approval Date 7/12/2017 Approved By Reimbursement Policy Oversight Committee IMPORTANT NOTE ABOUT THIS REIMBURSEMENT POLICY You are responsible for submission
More information4/4/2018. Telehealth-Credentialing, Privileging and Quality Oversight. Washington Association of Medical Staff Services Vancouver, Washington
Washington Association of Medical Staff Services Vancouver, Washington Telehealth-Credentialing, Privileging and Quality Oversight Jon Burroughs, MD, MBA, FACHE, FAAPL April 19, 2018 Telemedicine: The
More informationOIG Risk Areas: Anti- Supplementation; Therapy Services, Physicial Self-Referral & Hospice
OIG Risk Areas: Anti- Supplementation; Therapy Services, Physicial Self-Referral & Hospice Presented by: Ken Burgess, Esq. Paul Pitts, Esq. Suzie Berregaard, Esq. Where We ve Been & Today s Topics Review
More informationTelehealth. Telehealth? 6/1/2016. A tool for enhancing health care, communication and information.
Telehealth June 2016 Telehealth? A tool for enhancing health care, public Providing/receiving health, and health education health delivery care services and support, at using a distance. electronic communication
More informationAN ACT authorizing the provision of health care services through telemedicine and telehealth, and supplementing various parts of the statutory law.
Title. Subtitle. Chapter. Article. (New) Telemedicine and Telehealth - - C.:- to :- - C.0:D-k - C.:S- C.:-.w C.:-..h - Note (CORRECTED COPY) P.L.0, CHAPTER, approved July, 0 Senate Substitute for Senate
More informationCreative Solutions to Challenging Access Issues. The State of Telehealth in Our Region
Creative Solutions to Challenging Access Issues The State of Telehealth in Our Region Nebraska Hospital Association - October 25, 2017 Telehealth: Telemedicine Remote Monitoring Store-and-Forward Direct-to-Consumer/Primary
More informationLOUISIANA MEDICAID PROGRAM ISSUED: 06/09/17 REPLACED: CHAPTER 2: BEHAVIORAL HEALTH SERVICES SECTION 2.2: OUTPATIENT SERVICES PAGE(S) 8
Licensed Practitioner Outpatient Therapy includes: Individual; Family; Group; Outpatient psychotherapy; Mental health assessment; Evaluation; Testing; Medication management; Psychiatric evaluation; Medication
More informationTELEHEALTH REIMBURSEMENT
FACT SHEET CENTER FOR CONNECTED HEALTH POLICY The Federally Designated National Telehealth Policy Resource Center Info@cchpca.org 877-707-7172 TELEHEALTH REIMBURSEMENT Telehealth is a well-established
More informationTelehealth: An Introduction to Implementation and Policy Considerations. Angela Evatt, M.A., M.P.P
Telehealth: An Introduction to Implementation and Policy Considerations Angela Evatt, M.A., M.P.P Overview What is telehealth, how can it be used in care delivery, and what does it aim to accomplish? Value
More informationOklahoma Health Care Authority. Telemedicine
Oklahoma Health Care Authority Telemedicine Telemedicine Policy: OAC 317:30-3-27 Billing Technology 2 Telemedicine Applicability & Scope The purpose of the SoonerCare telemedicine is to improve access
More informationOutpatient Hospital Facilities
Outpatient Hospital Facilities Chapter 6 Chapter Outline Introduce students to 1. Different outpatient facilities 2. Different departments involved in the reimbursement process 3. The Chargemaster 4. Terminology
More informationTelemedicine Policy. Approved By 4/08/2015
Telemedicine Policy Policy Number 2016R0046B Annual Approval Date 4/08/2015 Approved By Payment Policy Oversight Committee IMPORTANT NOTE ABOUT THIS REIMBURSEMENT POLICY You are responsible for submission
More informationKPMG Digital Health Pulse April 2017
KPMG Digital Health Pulse 2017 April 2017 Research purpose and design To identify key perceptions about the pace of digital health adoption and key challenges to implementing virtual care programs at hospitals
More informationCHIA PRESENTATION HANDOUT
5055 E. McKinley Ave, Fresno CA 95407 Tel: (559) 251 5038 Info@ CHIA PRESENTATION HANDOUT 2018 CHIA CONVENTION & EXHIBIT SAN DIEGO, CA Transforming Health Care with Connected Health Technology: An Update
More informationOpportunities to Leverage Telehealth Within Your ACO Strategy
Opportunities to Leverage Telehealth Within Your ACO Strategy Shawn Valenta RRT, MHA Administrator of Telehealth Center for Telehealth Phillip Warr, MD Interim Chief Medical Officer Case Management and
More informationATA STATE TELEMEDICINE TOOLKIT Working with Medical Boards: Ensuring Comparable Standards For the Practice of Medicine via Telemedicine
ATA STATE TELEMEDICINE TOOLKIT Working with Medical Boards: Ensuring Comparable Standards For the Practice of Medicine via Telemedicine Tens of millions Americans benefit from remote health services every
More informationTelehealth and Nutrition Law and Regulations Holistic Nutrition Coalition
1 Telehealth and Law and Regulations Holistic Coalition Telehealth There are different definitions of telemedicine or telehealth depending on state law. Generally, telehealth or telemedicine is defined
More informationTelehealth in Peritoneal Dialysis Patient Management
Telehealth in Peritoneal Dialysis Patient Management Susie Lew, MD George Washington University March 3, 2018 Disclosures CareFirst Foundation: grant ACT/ The App Association: Steering committee member
More informationBuilding a Successful Telemedicine Program
Building a Successful Telemedicine Program Part 1 Ronald S. Weinstein, MD Founding Director, Arizona Telemedicine Program First Telemedicine Case Massachusetts General Hospital April, 1968 Warren Street
More informationTELEHEALTH & BEHAVIORAL HEALTH
TELE & BEHAVIORAL NATIONAL COUNCIL FOR BEHAVIORAL INSTITUTE October 2, 2017 877-707-7172 cchpca.org Mei Wa Kwong, JD Policy Advisor & Project Director DISCLAIMERS Any information provided in today s talk
More informationNATIONAL CONSORTIUM OF TELEHEALTH RESOURCE CENTERS
NATIONAL CONSORTIUM OF TELE RESOURCE S For the California Telehealth Resource Center Conference May 17, 2018 877-707-7172 cchpca.org Mario Mei Guttierez Wa Kwong, JD DISCLAIMERS Any information provided
More informationSTATE TELEHEALTH POLICY TRENDS. Legislative Summit 2016 Kate Blackman, Policy Specialist, NCSL
STATE TELEHEALTH POLICY TRENDS Legislative Summit 2016 Kate Blackman, Policy Specialist, NCSL Overview of telehealth Policy issues Reimbursement Licensure Patient Safety Recent state action Telehealth
More informationTELEHEALTH INDEX: 2015 PHYSICIAN SURVEY
TELEHEALTH INDEX: 2015 PHYSICIAN SURVEY Overview Telehealth is accelerating in 2015. As many as 37% of hospital systems have at least one type of telemedicine solution to meet a variety of objectives,
More informationCompliance Issues For Multi-Provider Collaborations: How To Spot & Avoid Potential Pitfalls
Compliance Issues For Multi-Provider Collaborations: How To Spot & Avoid Potential Pitfalls LeadingAge New York s Financial Managers Annual Conference Wednesday, August 31, 2016 Saratoga Hilton, Saratoga
More informationLEGAL CONSIDERATIONS FOR FQHCS: REIMBURSEMENT FOR TELEMEDICINE SERVICES
LEGAL CONSIDERATIONS FOR FQHCS: REIMBURSEMENT FOR TELEMEDICINE SERVICES SOUTH CAROLINA PRIMARY HEALTH CARE ASSOCIATION SOUTH CAROLINA PRIMARY HEALTH CARE ASSOCIATION 2017 STATE POLICY & ISSUES FORUM Jeanne
More informationAligned TeleHealth, Inc. On-site Staffing & TelePsychiatry
Aligned TeleHealth, Inc. On-site Staffing & TelePsychiatry Aligned s History Dr. Nitin Nanda, P.C. Founded in 2000 Founded as a Private Psychiatry Practice in Los Angeles by Dr. Nitin Nanda upon Completing
More information2017 Telehealth Policy for the National Rural Health Association
2017 Telehealth Policy for the National Rural Health Association Introduction Telemedicine has been around for decades, but is just now really becoming mainstream with the congruence of technology, lower
More informationTelehealth. Administrative Process. Coverage. Indications that are covered
Telehealth These services may or may not be covered by your HealthPartners plan. Please see your plan documents for your specific coverage information. If there is a difference between this general information
More informationThe Telemedicine Train is Leaving the Station: Don t be left behind
The heart and science of medicine. UVMHealth.org The Telemedicine Train is Leaving the Station: Don t be left behind Prepared by Norman Ward MD, Chief Medical Officer, OneCare Vermont Natasha Wither, DO,
More informationNavigating the Telehealth Landscape
Population Health Advisor Navigating the Telehealth Landscape Strategies for Financial Viability and Regulatory Compliance Michelle Seslar Senior Analyst, Population Health Advisor SeslarM@advisory.com
More informationTelemedicine: Improving Access to Specialty Care in Wisconsin s Rural Communities
Telemedicine: Improving Access to Specialty Care in Wisconsin s Rural Communities David Guggenbuehl, RN, MBA, Director Jessica Miller, RN, Telemedicine Program Manager Department of Regional Services and
More informationTelehealth/Telemedicine Online Visit
Telehealth/Telemedicine Online Visit Blue Cross Blue Shield and Blue Care Network 1 Telemedicine Medical Policies The Blue Cross Blue Shield of Michigan and Blue Care Network Medical Policies are attached
More informationChapter 2. Telehealth Regulatory Requirements
Chapter 2 Telehealth Regulatory Requirements 2.1 Introduction Sometimes referred to as telehealth practice standards, the rules governing where and how telehealth may be used to deliver care are largely
More informationREVISION DATE: FEBRUARY
Mary Ann Hodorowicz, MBA, RDN CDE, CEC, Owner, Mary Ann Hodorowicz Consulting LLC, Palos Heights, IL Coverage: In-Person Payable Places of Services Excluded Places for Part B Payment Excluded Places: 0
More informationATTENTION PROVIDERS. This bulletin does not supersede any provider enrollment requirements
EqualityCareNews MAY 2007 ATTENTION PROVIDERS This bulletin does not supersede any provider enrollment requirements CMS-1500 Bulletin 07-002 Wyoming Medicaid will pay for telehealth services that meet
More informationMaryland. Center for Connected Health Policy. Medicaid Program: MD Medical Assistance Program. Program Administrator: MD Dept. of Social Services
Maryland Medicaid Program: MD Medical Assistance Program Program Administrator: MD Dept. of Social Services Regional Telehealth Resource Center Mid-Atlantic Telehealth Resource Center PO Box 800711 Charlottesville,
More informationAVOIDING HEALTHCARE FRAUD AND ABUSE; Responsibility, Protection, Prevention
AVOIDING HEALTHCARE FRAUD AND ABUSE; Responsibility, Protection, Prevention Presented by: www.thehealthlawfirm.com Copyright 2017. George F. Indest III. All rights reserved. George F. Indest III, J.D.,
More informationAccount Management, Coding, Customer Service, Legal, Medical Management, Finance, Claims, Underwriting, Network Management
DEPARTMENT: Coding Reimbursement APPROVED DATE: POLICY DESCRIPTION: Telemedicine/Telehealth/Telecommunications/Televideo EFFECTIVE DATE: 6-24-04 PAGE: 1 of 4 REPLACES POLICY DATED: REFERENCE NUMBER: P-30
More informationUPMC Telehealth Program. Leveraging Advances in Technology to Transform Healthcare Delivery through New Models of Care
UPMC Telehealth Program Leveraging Advances in Technology to Transform Healthcare Delivery through New Models of Care UPMC s Telehealth Expansion Pediatric Specialty Inpatient Dermatology Pre & Post Operative
More informationTexas Medicaid. Provider Procedures Manual. Provider Handbooks. Telecommunication Services Handbook
Texas Medicaid Provider Procedures Manual Provider Handbooks December 2017 Telecommunication Services Handbook The Texas Medicaid & Healthcare Partnership (TMHP) is the claims administrator for Texas Medicaid
More informationProviding and Billing Medicare for Chronic Care Management Services
Providing and Billing Medicare for Chronic Care Management Services (and Other Fee-For-Service Population Health Management Services) No portion of this white paper may be used or duplicated by any person
More informationTelehealth in Alaska. Cindy Roleff, MS, BSN, RN-BC Telehealth Program Development Manager AFHCAN / ANTHC
Telehealth in Alaska Cindy Roleff, MS, BSN, RN-BC Telehealth Program Development Manager AFHCAN / ANTHC Why Telehealth? Patient Empowers them with additional choices Satisfaction Decreases disparities
More informationJOHNS HOPKINS HEALTHCARE
Page 1 of 16 ACTION: New Policy Effective Date: 10/01/2013 Revising : Review Dates: 03/29/16, 06/29/17, Superseding 09/01/17, 12/01/17 Archiving Retiring Johns Hopkins HealthCare LLC (JHHC) provides a
More informationCMS-1676-F 120. and makes a separate payment to the distant site practitioner furnishing the service.
CMS-1676-F 120 C. Medicare Telehealth Services 1. Billing and Payment for Telehealth Services Several conditions must be met for Medicare to make payments for telehealth services under the PFS. The service
More informationFlorida Tax Watch Telehealth Cornerstone Conference Telehealth Update November 19-20, 2014
Florida Tax Watch Telehealth Cornerstone Conference Telehealth Update November 19-20, 2014 Troy A. Kishbaugh Health Law Practice Group 301 E. Pine Street, Suite 1400 Orlando, FL 32801 407-843-8880 Sarah
More information3/27/2017. Historical Perspective. Innovative Model of Healthcare Delivery Using Telemedicine
Innovative Model of Healthcare Delivery Using Telemedicine Vinita Kamath MS RDN MHA Clinical Director, Nutrition Therapy Cincinnati Children s Hospital Medical Center CNM Conference March 20, 2017 Outline
More informationTelehealth Billing, Licensing, Reimbursement and Credentialing Issues Across State Lines
Telehealth Billing, Licensing, Reimbursement and Credentialing Issues Across State Lines Live tweet - #telehealth2015 Introduction and Session Notes Agenda Introduction and panel presentations: ~55 minutes
More informationPECULIARITIES OF BILLING AND CODING IN LTC OCTOBER 14, 2011
PECULIARITIES OF BILLING AND CODING IN LTC OCTOBER 14, 2011 PRESENTED BY ALVA S. BAKER, MD, CMD Maine Medical Directors Association Faculty Disclosures: Dr. Baker has disclosed that he has no relevant
More informationRECOVERY AUDIT CONTRACTORS
RECOVERY AUDIT CONTRACTORS RAC SUBSCRIPTION SERVICE Being Proactive Telemedicine Rule and CMS Updates May 10, 2011 2011 Aegis Compliance & Ethics Center, LLP 1 Faculty Brian Annulis, JD Partner, Meade
More informationTelehealth: Using technology in the delivery of healthcare
Telehealth: Using technology in the delivery of healthcare Using Telemedicine to Treat Chronic Disease in Rural Communities "Rural Americans face a unique combination of factors that create disparities
More informationHR Telehealth Enhancement Act of 2015
HR 2066 - Telehealth Enhancement Act of 2015 Rep. Harper (R-MS), Rep. Thompson (D-CA), Rep. Black (R-TN) & Rep. Welch (D-VT) Author Intent: To promote and expand telehealth application under Medicare and
More information