Telehealth has emerged as a cost-effective and extremely popular addition to in-person care for a wide range of patient needs. A recent survey revealed that 64% of consumers say they want to receive some, most, or all of their healthcare virtually or online in the future. To help your healthcare organization achieve its goals and get the most out of your telehealth program, we’ve identified five critical components that will help you to expand your program and navigate the latest telehealth rules and regulations.
1. Getting telehealth providers ready to work
In most cases, federal and state laws require providers delivering care to be licensed in the state from which they’re delivering care (the “distant site”) and the state where the patient is located (the “originating site”). So, if a provider lives in Washington and conducts a telehealth visit with a patient in Florida, he or she must be licensed in both Washington and Florida.
Fortunately, a majority of states have licenses or telehealth-specific exceptions that allow an out-of-state provider to deliver services via telemedicine (cross-state licensing), or licenses that allow them to provide care in a different state if certain conditions are met. It’s important to familiarize yourself with the licensing requirements for each state for telehealth.
Almost every state has their own licensure requirements for healthcare providers, but the Interstate Medical Licensure Compact (IMLC) streamlines the licensing process and makes it much simpler for healthcare practitioners providing telehealth services to hold licenses in multiple states. For the latest list of participating states and answers to frequently asked questions, visit imlcc.org.
Another tool that can speed up the licensing process is the Uniform Application for Licensure, a web-based application that improves license portability by eliminating a provider’s need to re-enter information when applying for licenses.
To deliver telehealth services, a provider must be credentialed for and have privileges at the facility they will be working for, regardless if they’re physically on-site. This can done by a traditional in-house credentialing process or by credentialing by proxy.
Licensing and credentialing providers for rural health facilities follows the same process as for those in urban areas. Healthcare facilities in rural locations seeking to streamline their telehealth credentialing process can benefit from credentialing by proxy, by allowing community and critical access hospitals to rely on the credentialing process of distant telehealth sites.
For additional rural-specific credentialing guidelines, visit the NRHA telehealth hub.
2. Getting reimbursed for telehealth
The most common question asked by healthcare leaders is how to get reimbursed for telehealth services. Reimbursement rates for telehealth services can vary by payer and whether you’re receiving payment from a private payer, Medicare, or a state Medicaid plan.
Payment parity laws, which are legislated at both the state (Medicaid) and federal (Medicare) level, also can affect reimbursement rates. The Centers for Medicare and Medicaid Services (CMS) has extended full telehealth payment parity for many provider services permanently, while others have only been extended through the end of 2022.
Pay parity laws
Currently, 40 states and the District of Colombia have pay parity laws in place. There are two types of pay parity:
Payment parity is the requirement that telehealth visits be reimbursed at the same payment rate or amount as if care had been delivered in person.
Coverage or service parity
Also referred to as access of parity, coverage or service parity requires the same services be covered for telehealth as they would be if delivered in person. Coverage parity does not, however, guarantee the same rate of payment.
Telehealth parity as of June 21, 2022
NOTE: Pay parity laws are subject to change. For the most current status and detailed state-by-state telehealth parity law legislation, visit the Center for Connected Health Policy website.
Click on the state link below to view telehealth parity information for that state.
3. How to bill for telehealth
Telehealth billing guidelines fall under three main categories: Medicare, Medicaid, and private payer.
In 2020, CMS broadened which telehealth services may be reimbursed for Medicare patients. With this expansion of care, Medicare patients are now able to receive virtual treatment from a wide range of providers — from physicians to licensed clinical social workers — and for a wide range of services.
CMS’ most updated fee schedule for Medicare reimbursement went into effect January 1, 2022. While CMS extended coverage, some telehealth reimbursements are set to expire at the end of 2022. Each state, however, has ongoing legislation which reevaluates telehealth reimbursement policies, both for private payer and CMS services.
Billing for Medicaid
Medicaid coverage policies vary state to state. In response to the public health emergency, many states moved to broaden the coverage for services delivered via Medicaid for telehealth services. In Spring 2022, the Center for Connected Health Policy (CCHP) released their executive summary of state telehealth laws and Medicaid program policy. As of publication, Medicaid has both coverage and payment parity laws in place in all 50 states and the District of Columbia.
Billing private insurance
Each private insurer has its own process for billing for telehealth, but 40 states and the District of Columbia have legislation in place which requires private insurance providers to reimburse for telemedicine. To find the most up-to-date regulations in your state, use this Policy Finder Tool.
Many healthcare facilities use the telehealth capability built into their electronic health record (EHR) system. Examples include Allscripts, Athena, Cerner, and Epic. Other technologies healthcare facilities use include live video conferencing, mobile health apps, “store and forward” electronic transmission, remote patient monitoring (RPM) systems, and video and audio technologies. All of these must be HIPAA-compliant.
Examples of HIPAA-compliant chat systems used for telehealth include:
5. Locum tenens and telehealth
Just like the locum tenens providers you bring on-site to your facility, locums providers performing care via telehealth still need to be fully licensed and credentialed, both in the locum physician’s state of residence and the originating site (patient’s state of residence).
Some locum tenens agencies provide malpractice coverage for telehealth locum providers, with the contingency that you have adequate processes and technology in place to protect them. Many locums agencies will assist in physician licensing and credentialing as well.
You will need to equip your locums with the needed technology, however, as most agencies will not provide this equipment.
For more information, see the Telehealth and locum tenens FAQ for healthcare facilities.