Government officials may not agree on much these days, but there are still a few important topics that can transcend the partisan divide. Throughout the course of the COVID-19 pandemic, both parties have recognized the importance of telehealth for keeping patients connected to their providers.
As part of the public health emergency (PHE) declaration at the start of the crisis, it was the Trump Administration that first oversaw key telehealth flexibilities for Medicare beneficiaries, such as allowing providers to use non-HIPAA compliant software when necessary, removing geographic restrictions for patients and providers, and loosening requirements around behavioral telehealth to expand care options for patients.
Progress continued under the Biden Administration. In 2021, Congress permanently waived geographic and originating-site restrictions for telemental health services, allowing patients to receive virtual behavioral healthcare services in their homes as long as they have met certain criteria in regard to establishing in-person relationships.
Soon after, CMS singled out FQHCs for some valuable additional benefits around telehealth for Medicare beneficiaries. In addition to adding digital assessment services to the FQHC arsenal, the 2022 Medicare Physician Fee Schedule establishes guidelines for FQHCs to receive payment parity for providing mental and behavioral healthcare through telehealth, including substance abuse care.
While Medicare only makes up a small proportion of billings for most FQHCs, payment parity makes it more financially viable to deliver these services at scale, helping FQHCs tackle one of the fastest growing needs for patients.
As the pandemic continues to bring challenges, Congress has once again united to support the care continuum. In March, legislators passed the Consolidated Appropriations Act for Fiscal Year 2022, which extends the bulk of the Medicare telehealth flexibilities for 151 days after the end of the COVID-19 PHE.
The PHE is currently slated to expire in July of 2022. If there are no further extensions of the PHE, that means that telehealth flexibilities will continue until November of 2022, giving providers a chance to make a real impact for patients – and giving Congress an opportunity to consider making these changes permanent.
What do FQHCs need to know about the continued flexibilities, and how can community health centers leverage the dynamic telehealth landscape to support their communities in need?
A new lease on life for some popular telehealth provisions
Thanks to the 2022 Omnibus Appropriations Legislation, providers will continue to take advantage of the following telehealth changes:
- Patients can participate in all covered telehealth services from anywhere, including urban areas and their own homes. Behavioral health patients can continue to receive care from any originating site after the extension ends, but other services may no longer be available to patients outside of approved originating locations.
- During the extension period, patients do not have to establish in-person relationships with their providers six months before a telemental health visit and conduct an in-person visit at least once a year afterward. In-person requirements for FQHCs is also being waived during this time.
- Providers will be able to bill for specific audio-only telehealth services in the same manner as audio/video telehealth.
In addition, Congress agreed to permanently allow a wider range of providers to provide certain telehealth services, including clinical psychologists, occupational and physical therapists, speech-language pathologists, and audiologists. New services, including low-intensity home visits and group psychotherapy sessions, are also eligible to be conducted virtually.
There is an important caveat to the 151-day extension, however. Legislators decided not to require CMS to offer payment parity between telehealth and in-person services during this time. FQHCs will still be able to take advantage of parity for services specifically included in the Medicare Physician Fee Schedule changes for 2022, but other services may not qualify for equal reimbursement.
What comes next for telehealth in a post-pandemic world?
151 days is approximately five months, which is likely to go by in a flash for overworked, under-resourced FQHCs. It may not seem like enough time to stand up new telehealth initiatives only to have the rules rolled back again before the year is out, but there is cause for optimism that many of the changes will be here to stay.
In the Consolidated Appropriations Act, Congress directed the Medicare Payment Advisory Commission (MedPAC) to conduct a study on the evolving telehealth landscape to be completed by early summer of 2023. The new study may inform future legislative efforts to make some of the aforementioned revisions permanent.
MedPAC has already signaled its willingness to embrace longer term changes with a March 2021 report on future policy ideas, the majority of which align tightly with the provisions of the latest extension.
Meanwhile, multiple bills have been introduced into both the House and the Senate to expand telehealth and make some of these changes permanent. Along with sustained popular enthusiasm for telehealth and support from a variety of prominent organizations and policymakers, this bodes well for the virtual care ecosystem.
Medicare’s influential position in the payer universe means that other health plans, including Medicaid and commercial options, might follow suit with making some of the changes permanent, creating a more open and adaptable telehealth environment for more types of beneficiaries.
Maximizing the value of the evolving telehealth environment
FQHCs have numerous opportunities to take advantage of the movement toward a more flexible world of virtual care delivery.
More than 90 percent have already done so during the pandemic, offering both medical and behavioral health services to their patient populations, noting that telehealth has resulted in improved access to care, lower no-show rates, better chronic disease management, and stronger patient-provider relationships.
Fortunately for FQHCs, the majority of state Medicaid programs are mirroring the activity on the federal level to some degree and investigating the best ways to make telehealth more viable for the long term.
According to a recent policy brief, in 2020, all states allowed reimbursement for primary care and behavioral healthcare delivered via telehealth. At least 42 states instituted payment parity for virtual Medicaid services and 47 states allowed for a patient’s home to be considered an originating site.
Remote patient monitoring, asynchronous telehealth, and even virtual check-ins are also gaining ground at the state level, significantly enhancing the ability of FQHCs to stay in contact with complex patients or those facing barriers to accessing traditional care.
While state Medicaid programs may differ in how long they allow these flexibilities to continue, it’s clear that the floodgates have been opened. FQHCs now have to decide whether they wish to lean into telehealth and continue to develop their competencies with virtual care.
For those participating in value-based care arrangements, telehealth offers a way to engage with patients who may not seek traditional care, including those who experience socioeconomic barriers. This may make it easier to stay on top of rising risks and provide preventive care in a timely manner, thereby improving the likelihood of improving outcomes and earning shared savings.
Related: Download our guide to better understand what a value-based care arrangement looks like for your FQHC.
However, FQHCs will need to make a concerted effort to connect with traditionally underserved populations, including older individuals, people of color, and those with limited English and digital proficiency, all of whom tend to use telehealth at lower rates than other groups.
Developing telehealth as part of a comprehensive, coordinated approach to value-based care will be essential to reduce disparities, make the most of ongoing flexibilities in both Medicare and Medicaid, and leverage telehealth as a way to improve long-term financial sustainability.
Using this time to enhance and expand telehealth capabilities as part of the larger push toward more value-driven care may position FQHCs well for a future in which remote interactions are an integral part of the healthcare delivery experience.
The few months will likely be full of activity in the telehealth policy space as lawmakers and healthcare stakeholders collaborate to further reform the virtual care ecosystem. FQHCs will need to keep a close eye on any changes and actively contribute to the national dialogue around remote care as they work to take advantage of what telehealth has to offer to providers and patients.