The evolution of telehealth beyond the pandemic
Answers in Practice
By Olivia Barry, Manager, Practice Management, June 1, 2024
Each month, DermWorld tackles issues “in practice” for dermatologists. This month, practice management staff explain changes to telemedicine after COVID-19.
It has been more than a year since the end of the COVID-19 public health emergency (PHE). The PHE brought on a surge of telemedicine utilization, pushing policymakers to quickly create temporary telehealth flexibilities and regulations to mitigate the spread of the virus while supporting continuity of care. Since then, teledermatology has become a preferred method of care among patients and physicians, providing patients with easier access to care, amid an uptick in physician utilization with an AAD member survey revealing 67% of AAD members expect to use it once a week or more (see chart below).
However, the expiration of the PHE in May 2023 left clinicians uncertain about the future of telehealth policies as some flexibilities have expired or changed, while others remain until the end of 2024. This article offers a concise summary of post-PHE telehealth policies, expectations after 2024, and teledermatology resources to optimize workflow and virtual care efficiency.
Telehealth flexibilities ending after Dec. 31, 2024
The Consolidated Appropriations Act, 2023 (CAA) extended many of the telehealth flexibilities put in place during the PHE until Dec. 31, 2024. Additionally, the 2024 Final Rule extended telehealth-specific flexibilities through 2024 to coincide with the CAA. Review the extended policies below.
Originating and geographic site
The Center for Medicare and Medicaid Services (CMS) will continue to waive the originating site requirement, which means Medicare patients can utilize telehealth services anywhere in the United States. As a reminder, dermatologists must still follow the state licensure laws of the state where the patient is located at the time of visit.
Resident supervision
CMS will continue to allow virtual supervision of residents in all residency training locations. Through 2024, teaching physicians can use audio/visual real-time communication technology to be present when the resident furnishes Medicare telehealth services. Further, teaching physicians and residents do not have to be co-located.
Direct supervision
CMS will continue to allow direct supervision by a supervising practitioner through real-time audio/video communication. CMS has temporarily adjusted the definition of direct supervision to include the “virtual presence” of the supervising practitioner via real-time audio-video technology, ensuring immediate availability for assistance and guidance during the service.
Coverage for Medicare telehealth service list including audio-only
CMS will continue to provide coverage and payment of telehealth services included on the Medicare Telehealth Services List. This list includes audio-only services which CMS will reimburse for Medicare patients through 2024.
Rural Health Clinics (RHCs) & Federal Qualified Health Care Centers (FQHCs)
CMS will continue payment for telehealth services furnished by RHCs and FQHCs using the methodology established for those telehealth services during the COVID-19 PHE.
Medicare enrollment address
Clinicians who render telehealth services from their homes can list their practice address instead of their home address on their Medicare enrollment through 2024. Dermatologists can edit or add their address to their Medicare enrollment file by reaching out to the Medicare Administrative Contractor (MAC) in their jurisdiction through the provider enrollment hotline.
New telehealth policy in 2024
Non-facility payment rate for patients in their home
Telehealth services provided to a patient who is in their home will be paid at the non-facility physician fee schedule (PFS) rate. These telehealth services provided in the patient’s home are billed using Place of Service Code (POS) 10 and will be reimbursed at the higher non-facility rate. All telehealth services provided in locations other than the patient’s home should be billed using POS 02 and will be reimbursed at the PFS facility rate.
Keep in mind, these telehealth flexibilities do not apply to private payers. The AAD recommends that practices check with private payers before providing the service to manage appropriate reimbursement expectations.
Enhance telehealth in your practice
Now that you’re up to speed on telehealth policies following the PHE expiration, explore the AAD’s telehealth resources to ensure adherence to telehealth regulations, streamline telehealth workflow, and utilize accurate billing codes for teledermatology.
Review the AADA’s Teledermatology Standards that outline the appropriate use of telemedicine and establish guidelines for the Academy to advocate for responsible telemedicine platform technology and telehealth reimbursement.
Learn more about the fundamentals of teledermatology. You’ll find information on teledermatology benefits, methods, patient guidance, compliance considerations, licensing across state lines, and more.
Check out the AAD’s sample workflow for teledermatology integration, tailored for small or solo practices. The process outlines technology setup, scheduling, check-in, appointments, and follow-up visits. Customize it to suit your practice needs.
Visit the coding page for teledermatology for coding and reimbursement guidance, including a flowchart, coding guide, and details on billing arrangements pre- and post-PHE for telehealth services.
Earn CME credit with the online teledermatology course Making Teledermatology Work for You: Practice Integration, Training, and Coding. Developed by the AAD Teledermatology Committee, this course focuses beyond the introduction to telehealth. It offers patient guidance for telehealth visits, physician and staff guidance, pitfalls that could occur and how to handle or avoid them, as well as information on coding and reimbursement.
Telehealth beyond 2024
Once telehealth flexibilities expire at the end of 2024, what can dermatologists expect next? While we cannot say for sure, CMS is currently reviewing and finalizing the above listed telehealth policies to determine whether they will be extended, made permanent, or removed beyond 2024. Despite ongoing uncertainties, the Academy remains committed to advocating for telemedicine policies that prioritize patients and ensure equitable reimbursement for physicians. See more details on the AADA’s advocacy efforts on telehealth regulation.
As telehealth flexibilities near their end in 2024, it’s essential for dermatologists to stay informed about evolving teledermatology policies. By utilizing the guidance and resources outlined in this article and staying proactive on telehealth regulations, dermatologists can continue to deliver high-quality care to their patients and ensure compliance with current policies.
More guidance and information
