Prior to the pandemic, only 15% of healthcare providers reported using telehealth regularly. Some weren’t equipped with the technology needed to do so. Others were impeded by limited insurance coverage, varying federal and state policies and regulations and parity laws.

However, once COVID prompted a global pandemic, telehealth use experienced an unprecedented, accelerated expansion. It provided numerous benefits by facilitating greater access to care, reducing risk for COVID transmission, conserving scarce medical supplies, and reducing strain on healthcare capacity and facilities while supporting continuity of care. It continues to provides benefits as we “scratch the surface of the potential of this new manner of health care, and the degree—and speed—to which it is embraced remains to be seen.”

Looking back: the accelerated expansion of telehealth

A number of legislative revisions and other changes by the Centers for Medicare & Medicaid Services (CMS) and other government agencies made the telehealth expansion possible. In addition to instituting payment parity between telehealth and in-person care and including live video on the list of eligible services, rules were broadened for telehealth for mental health and occupational and speech therapy services.


Similarly, some payers announced payment parity for telehealth for the duration of the pandemic, with insurers paying out anywhere from 2 to 10 times more per month for telehealth services last year as compared to 2019. To offer some financial incentive, the Department of Human and Health Services (HHS) through the Health Resources and Services Administration (HRSA) awarded $15 million to 159 organizations across five health workforce programs to increase telehealth capabilities in response to the COVID-19 pandemic. 

According to a recent survey, more than 77% of doctors surveyed used telehealth for the first time because of COVID-19. Usage of the technology increased during the initial March to April 2020 peak from less than 1% of visits to as much as 80%. More than 95% of HRSA-funded health centers reported using telehealth during the pandemic, and nearly 25 million Medicare beneficiaries received services via telehealth between mid-March and mid-October of 2020.

Reviewing legislative updates

More changes might be made to existing telehealth rules and regulations in the near future. Without such revisions to existing legislation, most telehealth activity will likely once again be billed at 80% the rate of an in-office visit.

On April 15 of this year, HHS announced that the Public Health Emergency (PHE) declaration for COVID19 will be renewed for another 90 days, extending it through July 19, 2021. There are no definitive plans yet on how states and the federal government will regulate and reimburse for telehealth services when temporary telehealth policies expire at the end of the PHE.

telehealth options

Last year, there were a total of 244 Medicare regulatory changes that impacted clinicians, hospitals and other healthcare providers during the pandemic. Most of these focused on payment systems and quality programs, conditions of participation, provider capacity, workforce and benefits, and care management. Only 14 of these changes, though, permanently altered Medicare regulations. CMS announced in December 2020 that 60 of the 144 telehealth services newly offered during the pandemic will become permanent. 

Along with expanded Medicare coverage for telehealth in the 2021 final rule, the federal government passed legislation in response to the COVID-19 PHE. This legislation implements the following flexibilities:

  • lifts location and geographic restrictions on telehealth
  • relaxes qualifying technology requirements
  • expands the list of Medicare-covered services
  • adds distant site practitioners
  • eases in-state licensure requirements
  • allows billing for certain hospital services furnished by clinical staff to beneficiaries in their homes
  • permits direct supervision via telemedicine
  • allows the provision of telehealth equipment in certain contexts
  • provides flexibility to reduce or waive cost-sharing for telehealth visits
  • pays for telehealth services at the in-person rate based on place of service
  • allows Qualified Medical Professionals to perform Medical Screening Examinations via telehealth
  • removes frequency limitations on subsequent hospital care and nursing facility care services

Exploring industry recommendations

The American College of Physicians (ACP) has recommended that CMS maintain payment parity between telehealth and in-person visits and permanently extend the policy waiving geographical and originating-site restrictions. The American Psychiatric Association (APA) is calling on Congress to permanently lift all restrictions that fully enabled the utilization of telehealth during the pandemic.

The Medicare Payment Advisory Commission (MedPAC), endorses Congress acting in the following ways:

  • to continue some of the PHE telehealth expansions temporarily (one or two years after the PHE) to gather additional evidence about the impact of telehealth on beneficiary access to care, quality of care and program spending
  • to continue Medicare coverage for telehealth services regardless of where a beneficiary is located
  • to cover audio-only services if there is potential for clinical benefit
  • to pay the physician fee schedule facility rate for telehealth services provided by providers in distant sites when the PHE ends while collecting data on the costs that practices incur in using telehealth, as was done before the PHE

virtual care appointment

CMS announced that it is commissioning a study of its telehealth flexibilities provided during the PHE. The study will explore new opportunities for services where telehealth and virtual care supervision and remote monitoring can be used to more efficiently bring care to patients and to enhance program integrity, whether they are being treated in the hospital or at home.

Considering the future of telehealth 

Virtual care is indeed a cost-effective and convenient mode of delivery, but it “may represent an important financial threat to practices and centers with traditional delivery structures such as fee-for-service or to those with significant capital investments in existing facilities.” Legislative changes and recommended protocols from the healthcare industry point to the need for a more intense examination of telehealth’s advantages and challenges and for reimbursements to be further addressed. 

Although it’s only one of the tools providers can use to aid in their transition to value-based care and do their part in reducing healthcare spending, it’s one that is a pivotal component in improving the quality of care through the use of technology.

At Harmony, we’re primed to deliver highly qualified reimbursement experts who can drive strategy and lead your organization into a better tomorrow.

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