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Regs & Eggs - January 16, 2020

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Advocating for Emergency Telehealth Reimbursement

Innovations around telehealth are a critical way to give patients greater access to an emergency physician in an inner-city or rural emergency department (ED). Telehealth access from the ED setting to other medical specialists such as neurologists or psychiatrists can help connect patients more quickly with specialty care and reduce delays in critically needed treatment. It can also reduce the time patients struggling with mental health issues remain in the ED waiting for a psychiatric bed to become available (a process commonly known as “boarding”). Finally, utilizing telehealth can help smaller hospitals treat more of their patients with emergency medical conditions instead of transferring them.

Different types of emergency care models have already been tested, from “direct-to-consumer” models to approaches that involve a hub that connects emergency physicians to EDs in remote locations or allows emergency physicians to provide consultations for specific clinical conditions. In general, studies have shown that physicians and patients are extremely satisfied with the care being provided through these models, and costs have decreased due to avoided ED visits and inpatient admissions.

While many innovative telehealth pilots have proven to be successful, a major barrier to the sustainability of these efforts is that Medicare does not reimburse for emergency telehealth services. The Centers for Medicare & Medicaid Services (CMS) maintains a list of telehealth services that Medicare reimburses and goes through an annual process of updating that list. CMS first allows the public to submit requests for new services, and then decides whether to accept or reject those requests in the annual physician fee schedule (PFS) reg. It has proven quite challenging to get emergency services added to CMS’ list since the agency uses extremely stringent criteria to review requests for services that are not performed in the office setting. In 2017, ACEP formally requested that CMS add ED evaluation and management (E/M) and ED observation services to the list of approved Medicare telehealth services. However, CMS rejected our request because the agency believed we did not provide enough compelling evidence to meet their strict criteria.

Recently, we took another crack at requesting that CMS add ED E/M and observation services to the list, providing additional evidence to meet CMS’ criteria. We submitted the request in time for CMS to consider adding the services to the list in 2021. We should know more by the summer (when CMS releases the 2021 PFS proposed reg) whether CMS is likely to accept our request.

While we are hopeful that CMS will add emergency telehealth services to list of approved Medicare telehealth services, this request is only part of our regulatory and legislative strategy for promoting the use of emergency telehealth services. We have also worked with Sen. Schatz (D-Hawaii)'s office on the CONNECT for Health Care Act, which was introduced in November 2019. This bill removes geographic restrictions on certain originating sites for emergency medical care services and asks CMS to revise their stringent criteria for adding new services to the list of approved Medicare telehealth services.

If you are interested in learning more about emergency telehealth or are already highly engaged in providing these services, I encourage you to become a member of ACEP’s telehealth section if you aren’t already. This section is extremely active and acts as ACEP’s collective resident expert on this issue. To join the telehealth section, please click here.

Until next week, this is Jeffrey saying, enjoy reading regs with your eggs!

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jeff headshot.PNGIf you have any questions or want to weigh in on other regulatory items, feel free to email me: jdavis@acep.org.
Jeffrey Davis is the Director of Regulatory Affairs at the American College of Emergency Physicians (ACEP). He manages ACEP’s formal response to federal policies and works with federal agencies and other stakeholders to help advance ACEP’s federal affairs agenda. Prior to that, Jeffrey worked in the Budget Office at the U.S. Department of Health and Human Services for nearly eight years. Jeffrey came to the Government as a Presidential Management Fellow, and in his position in the Budget Office, he advised top level officials on major budgetary and policy considerations within Medicare and prepared detailed analyses of Medicare regulations and legislation. Jeffrey has a Masters of Science in Health Policy and Management from the Harvard T.H. Chan School of Public Health and a Bachelors of Arts degree from Duke University.

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