Due to the COVID-19 Public Health Emergency, there has been a sharp increase in demand for telehealth services. In response to the demand for safe avenues for providing health services, the federal government is encouraging health care professionals to use telehealth to see patients when appropriate.
In an effort to encourage providers to implement telehealth services the Department of Health and Human Services (HHS) Office of Civil Rights has issued a Notification of Enforcement Discretion allowing HIPAA Flexibility when providing telehealth services during the COVID-19 Public Health Emergency.
For more information on the Notification of Enforcement Discretion see our blog post: “HHS Notice of Enforcement Discretion Around Telehealth”.
The Centers for Medicare and Medicaid Services (“CMS”) has also so sought to encourage the implementation of telehealth by expanding medical providers’ ability to get reimbursement for telehealth services. States and private insurance companies are following CMS’s lead and expanding coverage of telehealth services.
While many of these changes are temporary there are signs that a more permanent shift is occurring that will outlast the current COVID-19 Public Health Emergency.
“A Pandemic Benefit: The Expansion of Telemedicine”, The New York Times
Providers should be using this opportunity of increased flexibility to implement or expand telehealth services. Implementing telehealth services will allow providers to meet increased demand due to the COVID-19 Public Health Emergency and will also help providers building the telehealth infrastructure for a post COVID -19 expansion of telemedicine.
Even with the increased regulatory flexibility, implementing telehealth services requires planning, especially if you intend to continue providing telehealth services past the current COVID-19 Public Health Emergency.
The Department of Health and Human Services has compiled several resources to help providers integrate telehealth into their practice. These resources provide guidance on getting started, planning your telehealth workflow, preparing patients for telehealth, policy changes during the COVID-19 Public Health Emergency, billing and reimbursement, and legal considerations. These resources can be found on the Health and Human Services website: Telehealth – For Providers.
Before implementing or expanding your organization’s telehealth services, you should consult with experts to help you navigate the different elements you must account for when implementing telehealth services. Knowledgeable consultants, like JTG Consulting Group, LLC can help your organization set up or expand your telehealth system while allowing your organization to continue focusing on its main mission of providing healthcare.
Expansion of telehealth will have long lasting policy, legal, regulatory, social, and technological implications. It has the potential make healthcare more efficient and less expensive, facilitating the expansion of health services to underserved communities like rural and minority communities. It also has the potential to exacerbate current healthcare inequalities. It will take years of policy, legal, regulatory, social, and technological finetuning before we achieve the full potential benefits of telehealth. The current COVID-19 Public Health Emergency has jump started this process. Healthcare providers would be wise to start addressing this shift before they get left behind.
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