April 07, 2020
Virtual solutions have been a hotbed of innovation within the health care landscape, with telehealth services increasingly delivering on the promise of added user convenience, advanced monitoring potential and new care pathways. As we continue to grapple with the global pandemic, telemedicine in particular, or the virtual delivery of health care services, minimizes the exposure risk to those seeking care and enables physicians to continue seeing patients needing routine care during periods of social distancing.
Telemedicine has emerged as a preferred way to receive routine medical care, as conserving health care resources remains crucial in the fight to contain and treat those who have contracted the novel coronavirus. Its utilization also helps preserve health care facilities for those who must be seen in person for their conditions, whether they are related to COVID-19 or as part of other essential care. Furthermore, access to telehealth provides an avenue whereby illnesses can be treated more upstream, before more serious and expensive complications develop.
Utilization and engagement in telemedicine have accelerated rapidly since the beginning of the pandemic. Provider groups are also offering phone visits directly through their internal platforms, further expanding the types of visits that can be delivered virtually. While such visits are predominately for general medicine, they also may include specialist visits and services related to behavioral health. Employees are more receptive to utilizing virtual solutions and are actively seeking to do so during times of mandatory quarantine and stay-at-home orders.
Traditionally, physician offices received different (and often lower) reimbursement rates for services delivered over the phone or through other virtual means compared to in-person visits.1 In response to the increased demand for telehealth services and to facilitate access to necessary services for their patients in times of mandatory social isolation, the Centers for Medicare and Medicaid Services (CMS) has deemed certain telehealth services as equivalent to face-to-face visits for payment purposes. It is important to note that these services do not have to be COVID-19 related.2 Employers should check with their health plans if similar reimbursement rate changes are being made for the telephonic visits within the commercial plans. Raising reimbursement rates provides a financial incentive for physician offices to transition more visits to virtual formats, as the previously lower payments may have made it less feasible to do so.
Strategies for Expanding Telehealth Services
Employers, along with their health plan and vendor partners, can consider enhancing or expanding telemedicine access in the following ways:
- 1 | Extending access hours: Health plans and other telemedicine providers have worked to expand virtual care access through extended hours for telehealth services and nurse hotlines to better accommodate increased call volumes.
- 2 | Waiving/reducing member cost sharing for telehealth visits: Given the unique circumstances of social distancing, and in some jurisdictions, full quarantining, making telemedicine as easy to access as possible is ideal. In March 2020, the Families First Coronavirus Response Act and CARES Acts were signed into law: These include provisions allowing HSA/HDHPs to not only cover COVID-19 testing and treatment but to do so for all telemedicine/remote care services, without a deductible or with a deductible that is lower than the minimum self-only/family deductibles.3 If costs are a concern for employers, this could be a temporary plan design adjustment as a response to the global pandemic.
- 3 | Promotion of other virtual benefits and program offerings: Primary care related telemedicine has garnered the most attention with respect to strategies to minimize the strain on the U.S. health care system and provider workforce. However, employers have a unique opportunity to emphasize the importance of virtual health care solutions more broadly to their workforce. Such virtual solutions may include wellness programs, chronic condition management and coaching, as well as second opinion services.
- Clinical decision support tools can assist employees in determining whether elective procedures can be postponed, thereby reducing the burden on health care facilities tasked with delaying or rescheduling these services to prioritize COVID-19 treatment and preserve personal protective equipment (PPE). Second opinion providers may also offer “quick triage services”, in which clinical teams triage employees’ health concerns, check symptoms and refer them accordingly to the requisite telemedicine vendor. COVID-19 hotlines may be used for general questions and can be made available for all employees, including those not enrolled in benefit plans.
- During the current health and economic crisis, access to behavioral health resources is more critical than ever. Employers should consider making tele-mental health resources, such as programs improving resilience, sleep and other emotional well-being supports, available to address heightened feelings of stress or anxiety within the employee population. These solutions can also help members better acclimate to new daily routines resulting from office closures or mandated work-from-home policies. It is not uncommon for employers to continue offering access to EAP and other emotional support resources for employees laid off as a result of workforce reductions.
- Clear and effective communication of these solutions is essential to reducing employees’ anxiety: consider housing all relevant information and resources on a central, highly visible location such as a company intranet or landing page.
There are some challenges inherent to scaling up telehealth utilization and enhancing the scope of services. While many physician offices that otherwise would be slower to adopt widespread usage of phone/virtual visits have now embraced this transition, telemedicine vendors have been flooded with increased demand from their members. This has placed a strain on their staff, with many looking to increase their capacity through hiring more providers. Another important consideration is the basic requirement of consistent internet access needed to use telemedicine may not always be available in lower-income and/or rural households.
Although COVID-19 related services, including symptom evaluation, are exempt from cost sharing based on the provisions of the Families First Coronavirus Response Act, there are operational complexities to waiving copays or other fees associated with telemedicine related only to COVID-19. Determining how to separate COVID-19 claims and cases from others in order to waive cost sharing presents an ongoing challenge that health plans are actively working to address. Telehealth providers’ ability to discern between coding for an initial visit for COVID-19 symptoms and those for cold/flu may also vary.
Furthermore, some employers may want to offer access to telehealth to employees not enrolled in their company-sponsored health plan, as all of their employees are likely to be experiencing higher levels of stress and anxiety as well as difficulties with accessing brick-and-mortar care facilities. Nonetheless, expanding telehealth offerings to all employees (including those not covered by the group health plan) presents a unique set of challenges. Until now, employers generally have wrapped telehealth into their group health plans (allowing for compliance with ERISA, ACA and other laws for the whole package) and have not offered telehealth to non-health plan participants. Although the law is evolving quickly, offering telehealth as a stand-alone benefit still comes with legal risks. It is important for employers to coordinate with both HR and legal teams when exploring such an expansion.
In times of social distancing, telemedicine can be used as a safer way for employees to consult health care providers about potential COVID-19 symptoms and to access care for other needs. Employers may want to consider expanding access to existing and new resources. Communicating frequently with employees and highlighting resources available will help them choose the appropriate and convenient way to access the care they need.
- 1 | https://www.beckershospitalreview.com/finance/physicians-push-back-on-telemedicine-reimbursement-proposal.html
- 2 | https://www.mcdermottplus.com/insights/covid-19-telehealth-guidance-what-you-need-to-know/
- 3 | https://www.businessgrouphealth.org/resources/families-first-act-and-cares-act-mean-more-decisions-for-hr-and-benefits