Promoting Access to Quality Care Through Technology and Innovation Why Telehealth, Why Now? Industry Webinar November 9, 2016
Panelists Bill Boling Owner/Principal Boling & Company bill@bolingandcompany.com Mason Reid Associate Boling & Company mason@bolingandcompany.com Tanya Mack President Women s Telehealth tmack@womenstelehealth.com 404.478.3017
Agenda Regulatory Environment Licensing Compliance Physician-Patient Relationship Reimbursement Credentialing Privacy Telehealth in Action Physician Use Case, Rural Hospital Case, Home Monitoring Case Questions?
Housekeeping Handouts and Presentation Slides Questions for Panelists Azalea Health Telehealth Demo www.azaleahealth.com/request-a-demo
Why Telehealth, Why Now?
INTERSTATE LICENSURE Updated Nov. 2016 Out-of-state telemedicine licenses Other (e.g. border reciprocity, or consult only) Interstate Medical Licensure Compact Full state license required
COMPLIANCE - ESTABLISHING THE PHYSICIAN-PATIENT RELATIONSHIP Rule Examples of Approach States (e.g.) No requirement of in-person encounter No distinction between in-person, telemedicine Express permission of relationship established via telemedicine: Provider-patient relationships may be established using telehealth technologies so long as the relationship is established in conformance with generally accepted standards of practice. Colorado Medical Board Rule 40-27 (Aug. 2015) Alabama, Pennsylvania Louisiana, South Carolina, Colorado, Vermont, Virginia, North Carolina, Connecticut, Kentucky, Idaho, Tennessee, West Virginia, Missouri In-person encounter required with some exceptions Telemedicine-specific exceptions: The exam need not be in person if the technology is sufficient to provide the same information to the physician as if the exam had been performed face to face. 30-2635 Miss. Code R. 5.5 In-person exam effectively required: For new conditions, a patient site presenter must be reasonably available onsite at the established medical site to assist with the provision of care A distant site provider who provides telemedicine medical services at a site other than an established medical site for a patient's previously diagnosed condition must see the patient one time in a face-to-face visit before providing telemedicine medical care 22 Tex. Admin. Code. 174.6, 174.7** Georgia, Mississippi, Oklahoma* Texas, Arkansas *Excludes mere web-based video from definition of telemedicine; implications for mobile health **Currently being litigated
REIMBURSEMENT Private Insurance Parity: 30 states have enacted laws requiring private insurance parity! Recent additions: New York (payment parity); Rhode Island Recent developments: Alaska enacted telemental parity only; Mass. declined to enact parity again Medicaid: 48 states have some form of Medicaid reimbursement for telehealth. Scope of coverage varies dramatically. Medicare: Still limited to rural HPSAs or non-msas. List of covered services continues to expand. Reimbursement factors to consider: Patient setting requirements Geography/distance minimums Presenter requirements Reimbursable codes Billing methodology (status indicator, bill type, etc.) Disclaimer: The foregoing materials are provided for informational purposes only, and are not to be construed as legal advice.
Joint Commission and Medicare Conditions of Participation align to allow for a credentialing by proxy process Generally, these rules allow originating sites to use credentialing and privileging decisions of the distant site if various conditions are met Joint Commission standards: LD 04.03.09 MS 13.01.01 Medicare rules: 42 CFR 482.12(a) 42 CFR 482.22(a) 42 CFR 485.616(c) 42 CFR 485.635(c)(5) 42 CFR 485.641(b) CREDENTIALING Disclaimer: The foregoing materials are provided for informational purposes only, and are not to be construed as legal advice.
PRIVACY Does HIPAA apply? If PHI is transmitted or stored, it does. However, the videoconference itself, if not recorded, is not e-phi. Storage. Local storage or cloud storage? All locations must be secure. Transmission. If PHI is transmitted, network must be secure. No single standard for encryption. Must be reasonable under circumstances. Business Associates. Covered Entities must obtain BAA and satisfactory assurances. Business associates now directly liable for most violations and must obtain BAAs from subcontractors. Providers can minimize BA s access to PHI through opaque IDs not personally identifiable. Risk Assessment. Required of Covered Entities and Business Associates under Security Rule. Remember, APPS don t comply with HIPAA, PEOPLE comply with HIPAA! Many administrative requirements (emergency plan, policies & procedures, e.g.) apply to the person/organization, not the app
Telehealth Technology: It s on the Move! How it Works and Trends: Connectivity: Broadband (US), cellular, satellite transmission HIPAA compliant, subscription model common and cheap Hardware: When making an investment think platform vs. specialty Virtual exams with tools vs. AV connectivity only Carts being replaced by tools, laptops, Bluetooth monitoring Equipment prices are decreasing Software Moving toward cloud based vs. site managed Apps expanding rapidly Telemed integrated AV directly in the EMR
Telehealth in Action : Physicians Offices SCENARIO Five provider, urban, OB GYN office loses urban MFM provider at their hospital and patients complaining about out of pocket costs SOLUTION Contracts to add MFM provider in their office via telemedicine Configuration: Rent to own telemed cart x1 year <$500/month telemed network subscription used existing space and U/S machine Entity staffed RESULTS Telemed installation in < 45 days Operation 18 months Completed >1700 pt. high risk visits Generated < 60K/yr in new subcontract and facility fees Access to MFM resolved Convenient location Lower out of pocket costs High patient satisfaction Nationally presented
Telehealth in Action : High Risk OB - Rural Hospital SCENARIO >1 hr. drive to nearest hospital with MFM but hospital has 1500 births/yr. Cannot afford dedicated Dr., but OB s and hospital losing deliveries, NICU 50% full, transfers > 50 NICU pts/yr out. GOAL Transfer 50% or less pts out, keep service local, NICU>, add service line to hospital RESULTS Added 2 rooms to dedicated MFM U/S Consult Added telemedicine cart, subscription network, added 1 U/S tech Cost: hospital $100K to add service (equip + Staff) Generated approx. $750K in new service/facility fees In 1 st yr, transferred only 3 pts for fetal heart surgery Kept NICU busy generating > $3M new revenue for hospital All local
Telehealth in Action : Home Monitoring SCENARIO Patient became pregnant but unable to physically go to outpt visits. Local knew of telehealth capabilities possible to manage low risk OB at home using telemed? GOAL Receive all antenatal care via telemed safely and only go in to deliver at hospital RESULTS Azalea Health telemed available Taught pts to use home equipment (urine dip, weight, BP and Doppler) Needed Laptop w. camera + Internet browser + link to Azalea Patient Portal 2 home visits : (1 MA for labs, 1 st trimester + 18wk portable U/S Backup OB ported into some telemed visits prior to delivery Delivery planned/admitted Healthy baby girl!
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