The disruptive impact of the COVID-19 pandemic on our nation’s healthcare delivery system has been seen quite starkly in the unprecedented acceleration of telehealth adoption. The benefits of remote evaluation and monitoring of patients via phone calls, video calls, and chats are clear when it comes to maintaining separation of patients not only from providers but other patients in a crowded emergency department or other physical facility. On the flip side, providers who are under quarantine due to travel restrictions or possible exposure to the virus are still able to see patients virtually and add much needed capacity.

As part of its response strategy to this public health emergency, the current administration moved swiftly via the CARES Act to eliminate procedural barriers and establish the appropriate financial incentives to facilitate telehealth services for Medicare beneficiaries. Regulations which previously limited payments and blocked use of technology for telehealth visits have been removed. The Department of Health and Human Services (HHS) has agreed to “exercise discretion and waive penalties” for any HIPAA violations committed by healthcare providers who “serve patients in good faith through everyday communication technologies such as FaceTime or Skype” during the recognized national emergency time period. Clearly, the urgency of maintaining some continuity with providers and patients while also safeguarding everyone’s health were more than compelling reasons to act.

This has led to a warp-speed response by providers, who must be adequately prepared to implement telehealth services safely and effectively. Some of their key considerations along strategic and operational lines include the following:

Strategic considerations

Adoption and reimbursement of telehealth payments by payers has become more mainstream, making telehealth a more strategically viable line of business. Organizations wishing to move into telehealth will find an abundance of opportunity, though potential risk abounds as well. Understanding new legislation’s impact upon reimbursement and practice is critical to effective deployment of telehealth.

Previous requirements for having an established relationship and recent interactions with a provider have been waived. The list of services available via telehealth has been expanded and now includes E&M visits, behavioral health, and preventive health screenings. From a financial perspective, all telehealth visits will be reimbursed at the same rate as in-person visits – thus, billing/coding practices as well as underlying revenue cycle systems need to be updated and deployed expeditiously.

Operational rollout

Key operational considerations must first examine the types of telehealth interactions available. Looking to Medicare as a good example, CMS guidance identified and differentiated 3 types of COVID-19 virtual services that clinicians can provide to beneficiaries under the new 1135 waiver.

Telehealth Visit - Providers can use an interactive audio/video telecommunications system that permits real-time patient communication for office visits, hospital visits, and other services that would otherwise generally occur as an in-person encounter. CMS provides a full list of 101 codes that can be provided via telehealth online for reference.
Virtual Check-Ins - A brief patient interaction with a clinician can occur via a number of communication modalities, including synchronous discussion over a telephone or exchange of information through video or image. This is meant for patients with an established relationship with the provider, and where communication is not related to a medical visit within the previous seven days and does not lead to a medical visit within the next 24 hours. Existing Medicare coinsurance and deductibles would apply, and patients must verbally consent to receive a virtual check-in.
E-Visits - Non–face-to-face patient-initiated communications or online evaluation and management with an eligible clinician can occur via the use of an online patient portal over a seven-day period. Similar to virtual check-ins, patients must have a previously established relationship with the provider and have initiated the virtual inquiry.

Whichever flavor(s) of telehealth solutions are deployed, key operational components need to be planned for in the following areas:

Communication

Deploying easily understood materials to promote availability and value of telehealth options to patients
Ensuring providers understand new procedures regarding workflows and changes in authorization

Place and Space

Determining facility and physical space guidelines for providers and patients to conduct virtual visits.
Identifying hours of operation, shift schedules and communicating clearly to providers, patients and administrative support

Integrated Team

Ensuring adequate clinical and administrative capacity to support rise in telehealth demand
Defining and training on new roles and responsibilities as part of telehealth workflows for clinical and administrative staff

Workflows and protocols

Ensuring documentation of key telehealth procedures, including: patient triage, visit documentation, public health reporting requirement, and referrals to urgent or emergent care
Aligning and integrating telehealth workflows with overall care plan creation and follow-up activities

Information Technology

IT barriers can pose a significant risk to entry to those unprepared for the potential issues that can arise for patients and providers alike. Technology applications and infrastructure are a critical component to an overall telehealth solution, so from accessibility to interoperability to security, organizations should consider the following:

Accessibility - Difficulties can arise when trying to reach patients with high-bandwidth services like video chats at home, as over 146 million Americans don't have access to a low-cost plan for residential wired broadband. The issue is more pronounced in rural areas, with 1 in 5 individuals not having access to reliable high-speed internet. Thus, infrastructure capacity should be robust and diverse in order to accommodate an array of patients and connection speeds, some limited to mobile-only.
Interoperability - Often, telehealth solutions throughout a hospital are implemented at different times, with different vendors, and for different specialties. This patchwork installation can often lead to siloed data handling and redundant services leading to additional costs and confusion. When balancing competing desires between consumers vs. providers and clinical vs. business interests, drafting a single, holistic plan that considers all parties is key to preventing interoperability issues.
Technical support and maintenance - Security is not the only reason for maintaining technical support for telehealth services. Issues inevitably arise with technology - especially new technology. How such issues are addressed, and what type and level of support end users (both providers and patients) will receive are questions better answered prior-to vs. post go-live for telehealth solutions.

COVID-19 has served as a wake-up call to bring forward capabilities that challenge our notion of care delivery, and the lessons learned today will shape its future for years to come. Telehealth and telemedicine have been thrust into the spotlight and their role in our healthcare system is unlikely to diminish even after the current health crisis has passed. Telehealth has transformational potential for the healthcare industry, but as with any new innovation it will take refinement and optimization in order to actualize. Healthcare organizations who are thoughtful in rolling out these new capabilities will reap the benefits not only now but in the long-term.