Promoting Access to Quality Care Through Technology and ...€¦ · Industry Webinar November 9,...
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Why Telehealth, Why Now? Promoting Access to Quality Care Through Technology and Innovation Industry Webinar November 9, 2016
Transcript of Promoting Access to Quality Care Through Technology and ...€¦ · Industry Webinar November 9,...
Why Telehealth, Why Now?Promoting Access to Quality Care Through Technology and Innovation
Industry WebinarNovember 9, 2016
Panelists
Bill BolingOwner/Principal
Boling & [email protected]
Mason ReidAssociate
Boling & [email protected]
Tanya MackPresident
Women’s [email protected]
404.478.3017
● Regulatory Environment
○ Licensing
○ Compliance
○ Physician-Patient Relationship
● Telehealth in Action
○ Physician Use Case, Rural Hospital Case, Home Monitoring Case
● Questions?
Agenda
○ Reimbursement
○ Credentialing
○ Privacy
● Handouts and Presentation Slides
● Questions for Panelists
● Azalea Health Telehealth Demo
www.AzaleaHealth.com/request-a-demo
Housekeeping
Why Telehealth, Why Now?
INTERSTATE LICENSURE
Out-of-state telemedicine licenses Interstate Medical Licensure Compact
Other (e.g. border reciprocity, or consult only)
Full state license required
Updated Nov. 2016
COMPLIANCE - ESTABLISHING THE PHYSICIAN-PATIENT RELATIONSHIP
Rule Examples of Approach States (e.g.)
No requirement of in-person encounter
No distinction between in-person, telemedicine Alabama, Pennsylvania
Express permission of relationship established via telemedicine: “Provider-patient relationships may be established using telehealth technologies so long as the relationship is established in conformance with generally accepted standards of practice.” Colorado Medical Board Rule 40-27 (Aug. 2015)
Louisiana, South Carolina, Colorado, Vermont, Virginia, North Carolina, Connecticut, Kentucky, Idaho, Tennessee, West Virginia, Missouri
In-person encounter required with some exceptions
Telemedicine-specific exceptions: “The exam need not be in person if the technology is sufficient to provide the same information to the physician as if the exam had been performed face to face.” 30-2635 Miss. Code R. § 5.5
Georgia, Mississippi, Oklahoma*
In-person exam effectively required: “For new conditions, a patient site presenter must be reasonably available onsite at the established medical site to assist with the provision of care…A distant site provider who provides telemedicine medical services at a site other than an established medical site for a patient's previously diagnosed condition must…see the patient one time in a face-to-face visit before providing telemedicine medical care” 22 Tex. Admin. Code. § 174.6, 174.7**
Texas, Arkansas
*Excludes mere “web-based video” from definition of telemedicine; implications for mobile health**Currently being litigated
• Private Insurance Parity: 30 states have enacted laws requiring private insurance parity!• Recent additions: New York (payment parity); Rhode Island• Recent developments: Alaska enacted telemental parity only; Mass. declined to enact
parity again
• Medicaid: 48 states have some form of Medicaid reimbursement for telehealth. Scope of coverage varies dramatically.
• Medicare: Still limited to rural HPSAs or non-MSAs. List of covered services continues to expand.
• Reimbursement factors to consider: • Patient setting requirements• Geography/distance minimums • Presenter requirements• Reimbursable codes • Billing methodology (status indicator, bill type, etc.)
REIMBURSEMENT
Disclaimer: The foregoing materials are provided for informational purposes only, and are not to be construed as legal advice.
• Joint Commission and Medicare Conditions of Participation align to allow for a “credentialing by proxy” process
• Generally, these rules allow originating sites to use credentialing and privileging decisions of the distant site if various conditions are met
• Joint Commission standards:• LD 04.03.09• MS 13.01.01
• Medicare rules:• 42 CFR 482.12(a)• 42 CFR 482.22(a)• 42 CFR 485.616(c)• 42 CFR 485.635(c)(5)• 42 CFR 485.641(b)
CREDENTIALING
Disclaimer: The foregoing materials are provided for informational purposes only, and are not to be construed as legal advice.
PRIVACY
• Does HIPAA apply? If PHI is transmitted or stored, it does. However, the videoconference itself, if not recorded, is not e-PHI.
• Storage. Local storage or cloud storage? All locations must be secure.
• Transmission. If PHI is transmitted, network must be secure. No single standard for encryption. Must be reasonable under circumstances.
• Business Associates. Covered Entities must obtain BAA and satisfactory assurances. Business associates now directly liable for most violations and must obtain BAAs from subcontractors. Providers can minimize BA’s access to PHI through “opaque” IDs – not personally identifiable.
• Risk Assessment. Required of Covered Entities and Business Associates under Security Rule.
Remember, APPS don’t comply with HIPAA, PEOPLE comply with HIPAA!Many administrative requirements (emergency plan, policies & procedures, e.g.)
apply to the person/organization, not the app Disclaimer: The foregoing materials are provided for informational purposes only, and are not to be construed as legal advice.
Telehealth Technology: It’s on the Move!
How it Works and Trends:● Connectivity:
○ Broadband (US), cellular, satellite transmission○ HIPAA compliant, subscription model common and cheap
● Hardware: ○ When making an investment think platform vs. specialty○ Virtual exams with tools vs. AV connectivity only○ Carts being replaced by tools, laptops, Bluetooth monitoring○ Equipment prices are decreasing
● Software○ Moving toward cloud based vs. site managed○ Apps expanding rapidly○ Telemed integrated AV directly in the EMR
Telehealth in Action : Physicians’ Offices
SOLUTION
● Contracts to add MFM provider in their office via telemedicine
● Configuration: Rent to own telemed cart x1 year
● <$500/month telemed network subscription
● used existing space and U/S machine● Entity staffed
RESULTS● Telemed installation in < 45 days● Operation 18 months● Completed >1700 pt. high risk visits● Generated < 60K/yr in new
subcontract and facility fees ● Access to MFM resolved● Convenient location● Lower out of pocket costs ● High patient satisfaction ● Nationally presented
SCENARIO Five provider, urban, OB GYN office loses urban MFM provider at their hospital and patients complaining about out of pocket costs
Telehealth in Action : High Risk OB - Rural Hospital
GOAL
● Transfer 50% or less pts out, keep service local, NICU>, add service line to hospital
RESULTS● Added 2 rooms to dedicated MFM U/S
Consult ● Added telemedicine cart, subscription
network, added 1 U/S tech ● Cost: hospital $100K to add service
(equip + Staff)● Generated approx. $750K in new
service/facility fees● In 1st yr, transferred only 3 pts for fetal
heart surgery● Kept NICU busy generating > $3M new
revenue for hospital● All local
SCENARIO >1 hr. drive to nearest hospital with MFM but hospital has 1500 births/yr. Cannot afford dedicated Dr., but OB’s and hospital losing deliveries, NICU 50% full, transfers > 50 NICU pts/yr out.
Telehealth in Action : Home Monitoring
GOAL
● Receive all antenatal care via telemed safely and only go in to deliver at hospital
RESULTS● Azalea Health telemed available● Taught pts to use home equipment
(urine dip, weight, BP and Doppler)● Needed Laptop w. camera +
Internet browser + link to Azalea Patient Portal
● 2 home visits : (1 MA for labs, 1st trimester + 18wk portable U/S
● Backup OB ported into some telemed visits prior to delivery
● Delivery planned/admitted Healthy baby girl!
SCENARIO Patient became pregnant but unable to physically go to outpt visits. Local knew of telehealth capabilities… possible to manage low risk OB at home using telemed?
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