The ending of the three-year Public Health Emergency (PHE) has raised many questions and concerns regarding what that means for many ways of working in health care. Possibly the area of greatest concern for many is the continued availability of telemedicine.
Telemedicine – Pre-COVID
Before the onset of the COVID-19 pandemic, telemedicine was slowly but surely gaining traction.
Telemedicine – During COVID
While telemedicine was in use before COVID, one of the side effects of the pandemic was a boom in telemedicine adaptation, volume, and capabilities.
Not only did patients get more comfortable with virtual clinical encounters during this time, but so did in-person staff, hospital administration, revenue cycle services, and payors. The increase in adaptation is partially due to the PHE waivers issued by the Center for Medicare Services (CMS).
Telemedicine PHE Waivers
During COVID, there were many temporary policies put in place to enable maximum flexibility in delivery and access to care. Waivers included changes to:
- Telehealth licensing eligibility
- Site requirements (such as a patient needing to be in a rural area of specific health care site)
- Billing frequency for inpatient telehealth visits
- Virtual presence to meet direct supervision requirements
- Mental/behavioral health virtual visits
Some of the changes will end with PHE, with a built in 151-day implementation buffer, meaning changes under the waiver still apply through December 31, 2023. Others will become permanent policies.
Preparing Telemedicine Programs for post-PHE
With policy changes taking effect in the new year, it’s important to ensure telemedicine programs are ready to continue practicing effectively. Consider taking the following steps:
Review the licensing for your telemedicine team and location.
Different states have different policies when it comes to allowing out of state physicians to practice. Familiarize yourself with the requirements in your state and ensure the members of your telemedicine team are fully licensed to practice.
Keep virtual nurse practitioners and physician assistants state-based.
Nurse practitioners and physician assistants have even more variations across states when it comes to scope of practice. To continue using NPs and PAs virtually, as many do in virtual team triage situations, stick with in state models to avoid complications.
Ensure unrestricted DEA abilities
In March 2023, the DEA issued two notices of proposed rule-making and extended flexibilities through November 2023 while we await the publishing of the final rules. Recently, this deadline was extended through 2024. In the meantime, we encourage clinicians to register for DEA licenses in the states in which they would like to see patients. Each State DEA may have more stringent requirements.
Preparing for the Future of Telemedicine
Telemedicine has become an integral part of our health care system. Staffing shortages are projected to continue, patients have come to expect the convenience of virtual health care, and the need for access to equitable care is only growing.
The future of health care is unquestionably hybrid. Telemedicine is here to stay. The policies and regulations regarding virtual health will continue to evolve to meet the changing needs of the marketplace. To prepare telemedicine programs and clinicians for the future, focus on staying up with regulations, remaining agile, and delivering exceptional care to patients every time. SCP Health’s innovation team can help strategically advance your current programs toward the future of care delivery.
