The Centers for Medicare & Medicaid Services has recently issued proposed rules to expand telehealth services in skilled nursing facilities. It would apply to Medicare Advantage plans starting in 2020. One unique feature about this proposed rule is its application beyond rural areas, covering urban and in-home services.
This is atypical because most CMS telehealth reimbursement programs typically has a rural designation as a requisite feature. CMS’s proposed rule would allow SNF residents broader use of telehealth services in the facility under Medicare Advantage plans. Medicare Advantage plans would be able to include any Medicare Part B benefit the plan deems “clinically appropriate” to be furnished electronically by a remote physician or practitioner. Given these features, telehelth services may be a robust and critical option for future Medicare Advantage beneficiaries in SNFs, offering efficient coordination of care and more cost effective treatment methods.
The true value of telehealth is the residents’ regular access to physicians, which improves healthcare outcomes, and ultimately leading to less hospital re-admissions, a goal all SNF operators commonly strive for. The quality measure CMS seeks is cost-effective prevention. Beyond hospital re-admissions, CMS recognized that nurse reports identifying changes in a resident’s condition from using telemedicine saved $4,000 per SNF bed, savings approximately $5 million under the program.
Another ancillary benefit of telehealth services is the lessening of SNF staffing concerns. Staffing challenges is a common theme for most SNF operators. High attrition rates, finding qualified employees, on-boarding new employees and maintaining employees are costly burdens for most SNFs. Using telehealth may help alleviate staffing challenges, especially in geographical areas with shortages in qualified health care professionals.
The CMS proposed rule may be a pre-cursor to a change in traditional CMS perspectives on telehealth implementation in SNFs. CMS recently finalized separate rule to begin reimbursing for virtual check-in services, remote evaluation of recorded image, video submitted by patients and some prolonged preventive services.
Proponents of the new Medicare Advantage proposed rule are likely optimistic for the future of telehelth in SNFs, but expanding the scope of telehealth in SNFs will continue to be an on-going endeavor.
Richard Y. Cheng is an attorney and partner at Dykema Cox Smith, where he is a part of the Health Care Practice Group and the Cannabis Practice Group. Prior to his legal career, he worked as a licensed occupational therapist in Dallas.
