Last month, the Medicare Payment Advisory Commission (MedPAC) released a report to Congress, in which it advocated for temporarily continuing some of the telemedicine flexibilities implemented during the COVID-19 pandemic. MedPAC believes that by temporarily continuing the flexibilities, it will give Congress and the Centers for Medicare and Medicaid Services (CMS) more evidence about the impact telemedicine has on access to care, quality of care, and program spending.
During the COVID-19 public health emergency (PHE), Congress and CMS expanded coverage of telemedicine services, giving providers broad flexibility to provide telemedicine services in an effort to ensure beneficiaries have continued access to care while reducing their exposure to COVID-19. Without any legislative action, many of the flexibilities offered by Congress and CMS will expire at the conclusion of the PHE.
Historical Telemedicine Procedures
Prior to the COVID-19 PHE, Medicare paid for a limited number of telemedicine services only if they were provided to beneficiaries in a clinician’s office or a facility in a rural area. Even then, most of the telemedicine services were paid at the lower physician fee schedule (PFS) facility-based rate rather than the higher nonfacility rate, because the practice expenses associated with furnishing telehealth services were presumed to be lower.
However, during the PHE, CMS added more than 140 PFS services to the list of services it will pay for when delivered through telemedicine and changed the payment structure to paying the same rate it would pay if the service were provided in person (depending on the clinician’s location).
MedPAC’s Recommendation
MedPAC stated that CMS should allow one or two additional years (after the close of the public health emergency precipitated by COVID-19) to determine the impact telemedicine has. During that timeframe, Medicare should temporarily pay for specific telemedicine services irrespective of a provider’s location and CMS should continue to cover newly-covered telemedicine services and even some audio-only (no visual component) telemedicine care.
Once the public health emergency ends, Medicare should revert to paying the physician fee schedule facility rate for telemedicine events and collect data on the cost of providing telemedicine services to Medicare beneficiaries. MedPAC also noted that providers should not be allowed to reduce or waive cost sharing for telehealth services after the PHE.
MedPAC has previously recommended that policymakers use the principles of access, quality, and cost to evaluate individual telemedicine services before covering them under Medicare. While there have been some clinical trials comparing telemedicine and in-person care, there is no evidence on how the combination of telemedicine and in-person care affects quality and costs in the Medicare program. Perhaps COVID-19 was the impetus Congress and CMS needed to make lasting change on how telemedicine is treated.