LEADINGAGE ADVOCACY GOALS
- Advocate for permanent changes to Medicare, Medicaid, and commercial payer telehealth policy based on lessons learned from the coronavirus pandemic.
- Ensure all aging services providers are included in future permanent telehealth expansions
- Create an equitable payment policy for the post-pandemic era that balances providers’ costs with patient protections
- Promote the adoption of electronic health records, including funding and technical support.
- Promote the use of interoperable health information exchange between aging services providers and their partners including primary/acute care providers.
- Ensure equitable internet connectivity for all aging services providers and older adults, including in affordable housing where Wi-Fi access should be federally funded.
- Promote policies that support the use of technology to reduce social isolation and loneliness
- Address socia economic and racial disparities in consumer access to technology
LeadingAge members are saying:
- “Telehealth was not something we really used holistically before COVID and now it has become a critical part of providing services to our patients and families. We had to stand up our services through telehealth quickly but really allowed us to continue to provide care throughout the pandemic.”
- “Telehealth was an important solution in supporting residents for keeping in touch with their families and with their outside care providers throughout the pandemic.”
Massively increased flexibilities, particularly in the Medicare program, to utilize technology to deliver all types of care became an essential lifeline for our health care system during a time of unparalleled challenges and strains. If there is any “silver lining” to the coronavirus pandemic, it has been an increase in the use of technology to deliver care.
The ability to use telehealth during this emergency was vitally important to protect staff and patients’ health, but also to extend the reach of overextended health care personnel. Waivers in Medicare rules that allow for the home to be an originating site of care expanded the types of technology that can be used for telehealth visits (e.g., Facetime and even audio-only in some cases), and the expanding the types of providers that can bill for telehealth services are all massive changes from the pre-pandemic state of play.
The question now is how to capitalize on the progress made during the pandemic which in many ways has served as the “demo” of telehealth that many have asked for in the past. Concerns for the future including how to make sure that telehealth is incorporated into practice in an equitable, cost-effective (for both the government and providers), and accessible way – but what is clear is that we need to continue moving forward.
In addition to making permanent many of the pandemic flexibilities, aging services providers need support to maintain and upgrade technology and need adequate reimbursement from all payer sources to fortify and maintain their investments in delivering care via telehealth. Broadband investment, especially for rural and underserved areas, is critical to making sure telehealth is an accessible service nationwide – including in affordable senior housing communities, many of which lack connectivity and where federal investment in wireless internet capability is imperative. Continued investment in broader health IT to support information management and the secure exchange of health information are also critically important and need to be inclusive of aging services providers. Finally, those providers – like home health and PACE -- that have not been able to take full advantage of the expanded telehealth flexibilities need to be included.
ADVOCACY ACTION 2021
- Keeping key pandemic flexibilities: Support making key pandemic related telehealth provisions a permanent part of the Medicare program: permanently removing the geographic restrictions on telehealth; allowing the home to be an originating site of care beyond the public health emergency, and permanent expansion of the providers who can furnish telehealth services in both the physical and mental health arenas. We support the reintroduction of the Creating Opportunities NOW for Necessary and Effective Care Technologies (CONNECT) Act, the Telehealth Modernization Act, and others with changes that reflect the learnings of the pandemic.
- Allowable technology. We support continued flexibility in the type of modality allowable for video-audio connections (e.g. allowing the use of FaceTime or other smartphone technology) to utilize all tools available, including audio-only, to deliver telehealth services as appropriate and look to work with Congress on the intersection of accessibility and privacy (e.g., HIPAA concerns).
- Reimbursement for home health telehealth visits: We support legislative efforts (that allow virtual visits to be reimbursed by Medicare with appropriate guardrails and visit equivalency between in-person and virtual visits such as in the Home Health Emergency Access to Technology (HEAT) Act.
- Hospice face to face recertification. We support allowing the hospice face-to-face recertification to take place via telehealth on a permanent basis consistent with language in CONNECT Act, the Telehealth Modernization Act, and the Compassionate Care Act.
- Prevent a telehealth “cliff” after the end of the PHE. While we support the expansion of telehealth based on the experience of providers and patients during the pandemic, it is critically important that there not be a “cliff” where the flexibilities suddenly end, potentially cutting off access. We support a policy like that in the Protecting Access to Post COVID-19 Telehealth Act that would extend the public health emergency flexibilities for 90 days after the end of the PHE – though we would want to be sure it was inclusive of both legislative and regulatory flexibilities.
- PACE and Telehealth: We support the reintroduction of the Ensuring Parity in MA for Audio-Only Telehealth Act that would allow audio-only diagnoses that are made via telehealth to be used for purposes of determining risk adjustment to payments for PACE and Medicare Advantage programs.
- Housing and Technology. We support federal funding for the installation and service fees for wireless internet in all HUD-assisted senior housing communities’ units.
- Meaningful Use. Aging services providers were not included in previous funding efforts that supported health care providers’ transition to electronic health records (EHR) systems that contain the medical and treatment histories of patients. We will continue to advocate for funding to assist in allowing aging services providers to access the same EHR technology as their physician and hospital peers
- Nursing Homes and Telehealth: We support legislation that allows all nursing homes to use telehealth models to improve care, such as in the Reducing Unnecessary Senior Hospitalizations (RUSH) Act. The legislation establishes a pilot program to allow qualified physician group practices to provide acute care to Medicare beneficiaries in SNFs through a combination of telehealth and on-site clinical intervention. By augmenting SNF staff with after-hours clinical support through telehealth, the RUSH Act would allow CMS to test a new method for reducing hospitalizations, a major priority in the Medicare program.
- CMS Commissioned Study on Telehealth Flexibilities. CMS announced that they will commission a study of telehealth flexibilities provided during the COVID-19 PHE. The study will explore new opportunities for services where telehealth and virtual care supervision, and remote monitoring can be used to more efficiently bring care to patients and to enhance program integrity, whether they are being treated in the hospital or at home. We will advocate to be sure this study is inclusive of all settings.
- 1135 waivers. Advocate for review of telehealth and technology 1135 waivers to see which can be made permanent without Congress including utilization of telehealth for hospice routine home care visits and flexibility in licensure requirements in the Medicare and Medicaid program among others
- Monitor services allowed via telehealth. The CMS Calendar Year 2021 Physician Fee Schedule includes expanded Medicare services that can be administered via telehealth during and after the pandemic. CMS addresses a number of other issues, including frequency limits for SNF visits furnished through telehealth. We will monitor this growing list of services and advocate for others to be added as necessary. We will also specify which CMS SNF telehealth restrictions should be revised
- Remote Patient Monitoring. Work to ensure that all appropriate aging services providers can utilize and bill for remote patient monitoring to enhance their services.
- Advocate for the creation of claims codes or modifiers to document home health and hospice virtual visits. Hospice providers are utilizing telehealth for routine home care during the pandemic and home health providers are allowed to use virtual visits as part of their documented plan of care. We will advocate for the creation of claims codes or modifiers that will allow for the analysis of these encounters for a variety of purposes including quality measurement.
- Make demonstrations inclusive of telehealth. New and current CMMI demonstrations should include waivers to allow for the broad utilization of telehealth and technology to continue to build the evidence base for what role technology and telehealth will continue to play in healthcare delivery.
- Eliminate barriers to implement EHR interoperability. Continue to advocate for electronic health records interoperability and health information technology solutions that are aligned among our providers.
ACTIONS YOU CAN TAKE NOW
- Visit the Advocacy Action Center to let your representative and senators know your views on eliminating barriers for the expansion of telehealth services in the Medicare program.
- Host a Coffee Chat with Congress in your community to help your members of Congress understand how policies related to technology and not incorporating telehealth models in Medicare affect older adults.
- Mobilize with the Advocacy Champions toolkit and let your representatives and senators know your views on technology and telehealth for older adults.