Alliance for Connected Care: Alliance Highlights the Importance of a Special Registration to Allow Continuity of Care for Patients (9/12) - The Alliance was selected as a speaker at the DEA's public listening session. In our testimony, the Alliance discussed the importance of a special registration as the primary guardrail to identify and mitigate the risks of diversion in the prescribing of controlled substances through telehealth, and discuss implementation concerns for any proposed regulation. Read the full testimony here.
Alliance for Connected Care: Comment Letter on CY 2024 Physician Fee Schedule Proposed Rule (9/11) - The Alliance for Connected Care submitted comments on the Medicare Physician Fee Schedule (PFS) Proposed Rule for calendar year (CY) 2024. The Alliance emphasized the following overarching priorities:
The Alliance appreciates and supports the proposal from CMS to pay claims billed with POS 10 (Telehealth Provided in Patient’s Home) at the non-facility PFS rate. We applaud CMS for this choice, which recognizes that Medicare services provided via telehealth are simply a different modality for patients to receive the same care. However, rather than defining this payment rate around POS 10, we recommend that CMS consider instead offering the non-facility payment rate to any non-facility telehealth service.
The Alliance strongly supports the continued availability of direct supervision through telehealth for both the treatment of patients and the training of residents. We urge CMS to make expanded direct supervision through telehealth permanent. The option for virtual direct supervision is needed to strengthen our health system’s capability to meet longstanding health care challenges through increased access and a more flexible workforce.
We appreciate CMS efforts to expand access to remote monitoring for Medicare patients served by Rural Health Clinics (RHCs) and Federally Qualified Health Care Centers (FQHCs), but believe that the use of code G0511 as proposed will fail to expand access or improve health equity due to restrictions on how the code can be billed and the reimbursement rate which is far lower than equivalent services when offered by other providers.
We are optimistic for the revised review process for the Medicare Telehealth Services List but have some concerns with how this process is described – specifically around the thresholds for a code to be considered on a provisional status. We applaud CMS for attempting to provide more transparency in its process, and look forward to working with you to strengthen the process through which we evaluate which services are appropriate for delivery through telehealth.
Drug Enforcement Administration: Public Listening Session (9/12-13) - The Drug Enforcement Administration (DEA) held a two-day listening session and received comments from health care practitioners, experts, advocates, patients, and other members of the public to inform DEA's regulations on prescribing controlled substances via telemedicine. DEA also announced another comment period this fall for written comments before the telemedicine rules are finalized.
Selected News Coverage:
MedCity News: How 4 Mental Health Firms Want the DEA to Handle Virtual Prescribing of Controlled Substances (9/12) - Talkiatry, Array Behavioral Care, Iris Telehealth and Quartet Health sent a letter to the DEA asking for a special registration process that would allow for the prescribing of certain controlled medications via telemedicine. The four companies offer virtual psychiatry services, and while normally competitors, decided to band together to help patients maintain access to virtual prescribing of controlled substances, as well as to ensure their safety.
MedPage Today: DEA Gets an Earful About Telehealth Prescribing of Controlled Substances (9/12) - Psychiatry groups were among those concerned about the proposed 30-day prescribing limit. "The 30-day initiation period would not be adequate given the current wait times" for psychiatric care in many places, said Shabana Khan, MD, a psychiatrist who spoke on behalf of both the American Psychiatric Association and the American Academy of Child and Adolescent Psychiatrists. The psychiatry groups also oppose a DEA proposal to require telemedicine prescribers to note on the prescription that it was accessed via telemedicine.
Behavioral Health Business: We Consider This to be Our New Normal (9/12) - In total, the DEA lined up 61 commentators to present. Commenters presented to DEA Administrator Milgram and Deputy Assistant Administrator Prevoznik, who also asked follow-up questions. "I think that we have the opportunity to resolve a special registration process under this administration, that’s been evading multiple administrations for decades." - Talkiatry
Fierce Healthcare: Doctors and Lawmakers Say a Special Registration for Telehealth Prescribing is Overdue (9/13) - Doctors and telepsychiatry groups urged the DEA to create a "special registration" pathway to enable practitioners to prescribe controlled substances via telemedicine without a prior, in-person medical evaluation. The current proposed requirements will be operationally and technically burdensome to implement especially for complex health systems, Helen Hughes, M.D., medical director of the Office of Telemedicine at Johns Hopkins Medicine.
Senator Warner: Senators Express Concerns Over DEA's Proposed Rule on the Future of Telehealth (9/13) - Sens. Warner (D-VA), Thune (R-SD), Cortez Masto (D-NV), Capito (R-WV), Whitehouse (D-RI), and Sullivan (R-AK) sent a letter to DEA Administrator Milgram expressing support for the agency’s new engagement on a potential special registration for telehealth but sharing serious concerns over the agency’s proposed rules on the future of prescribing controlled substances via telehealth. The senators wrote, "We urge the DEA to consider feedback from health care stakeholders and apply the lessons learned from the COVID-19 pandemic to ensure patients maintain access to care through telehealth, while still minimizing diversion and fraud." Read the full letter here. For additional coverage, see Healthcare IT News.
California Health Care Foundation: Telehealth Use and Experiences Among California Adults (9/12) - California’s Medi-Cal program is leveraging telehealth to meet patient needs. Many of the telehealth coverage and reimbursement flexibilities enacted during the pandemic were made permanent in 2022, including payment parity for services provided in person or by telehealth. This issue brief uses data from the 2021 California Health Interview Survey (CHIS) to explore how telehealth use varies across subpopulations of adults in the state and reports how people rate their telehealth experience compared to in-person care.
Telehealth use varies by coverage type, race/ethnicity, and language
People on Medi-Cal use less telehealth
Less English proficiency is associated with less telehealth use
Black Californians are more likely to use telehealth
Most Californians who use telehealth like it as much as or better than in-person care
FAIR Health: Nationwide Telehealth Use Held Steady in June (9/7) - According to Fair Health's Monthly Telehealth Regional Tracker, telehealth sessions comprised 5.4 percent of claim lines in June, the same amount as the prior month. Mental health conditions continued to top the list of Fair Health’s five most common telehealth diagnoses for June. The median allowed amount billed for a one-hour psychotherapy visit was $103.
Health Affairs: A Study Of Patients’ Experiences Selecting Telehealth Versus In-Person Care (9/5) - Approximately one-third of behavioral health patients seeking therapy or medication visits said their clinicians did not offer both telehealth and in-person care. The study conducted by RAND Corporation found that 45 percent of behavioral health patients did not believe their clinicians considered their preferences for virtual or in-person care. In addition, 32 percent of respondents said they did not receive their preferred method of treatment. These findings suggest that patients’ modality preferences need to be a greater consideration in both clinical discussions and policy decisions.
Telehealth News and Market Developments
American Medical Association (AMA): Remote Patient Monitoring (RPM) Can Tackle Physician Burnout (9/8) - Chief clinical transformation officer at Ochsner Health says RPM can help with physician burnout, as it can unload some of their day-to-day tasks. The health system uses remote monitoring in its chronic disease programs for hypertension, diabetes, chronic obstructive pulmonary disease and dyslipidemia. Health systems should be thinking of ways to capture this information and process it in a way that doesn’t burden the system but takes care of people they’re responsible for.
Forbes: Using Digital Tools To Drive Convenience And Personalized Care (9/8) - RPM and telehealth provide the benefit of helping to reduce hospital stays for patients, decreasing emergency room visits, providing better health outcomes for those who live in rural areas and improving preventative management of chronic conditions. There are a wide range of prevalent, chronic conditions and illnesses such as high blood pressure, diabetes, heart conditions and asthma that can be tracked using remote monitoring. John Erwin, CEO of Carenet Health, shares Carenet's experience with telehealth.
Modern Healthcare: Telehealth in Schools Need More Funding (9/8) - A growing number of mental telehealth companies are offering their services to school-age children by working with local schools. Many received federal COVID-19 pandemic relief funds, but with usage of this money set to expire, companies are looking to prove their value to cash-strapped school districts. School districts are using both federal and state funds to provide telehealth mental health services to children. According to a survey from the Department of Education, 17 percent of public schools offered telehealth services throughout the 2021-2022 school year. Overall, 67 percent of schools increased mental health services and about 52 percent of schools used federal funds to launch mental health programs during this time.
mHealth Intelligence: Texas Pilots EMS Telehealth Project to Extend Trauma Care (9/5) - Texas is piloting a new project that will bring telehealth services to emergency medical services (EMS) settings in an effort to extend trauma care access in rural areas. The Texas House of Representatives passed a bill last month that establishes the pilot project called Next Generation 911. The law went into effect on September 1.The project will involve the Commission on State Emergency Communications and Texas Tech University Health Sciences Center working together to provide EMS and pre-hospital trauma care consultations through a telehealth service. The Texas Tech University Health Sciences Center, with the assistance of the commission, will design criteria and protocols for each telehealth service offered and the related education. They will also establish criteria to determine when a patient receiving care with telehealth support should be transferred to an emergency medical resource center.