10/29/09

American Recovery and Reinvestment Act : Unprecedented Opportunity for Health IT

{{w|Rahm Emanuel}}, U.S. Congressman.Image via Wikipedia
Health Information Technology and Economic and Clinical Health Act of 2009 (HITECH Act)


It has long been legislative practice in Washington, DC to package many large spending bills together in an omnibus package that gets passed with one vote by all members, rather than debate and vote on each measure independently. These practices are especially popular when one party has the near invincible majority in both houses, not to mention an overwhelmingly popular president in the White House. Obama's American Recovery and Reinvestment Act (ARRA) is essentially an omnibus spending bill  under the guise of a "stimulus package". The bundling of the HITECH Act, which radically alters the framework for implementing and managing electronic health records and general health care policy, into a spending bill sold to the American people as an "investment" in modernizing the national infrastructure and creating jobs is clever and near the top of early administration accomplishments.

Obama's first 100 days could easily be described by the phrase penned by Latin poet Hoarce carpe diem, popularly translated to mean "seize the day". The complete excerpt from the original poem reads, carpe diem quam minimum credula "seize the day and have no trust in tomorrow". I believe this completely captures Obama's mindset as he proactively spearheads efforts from the Oval Office to regain control  during a time of economic crisis and reinstate confidence in the capitalist system. The purpose driven and institutionally significant changes embedded in the fine print of the ARRA shows quite clear that Obama and his Chief of Staff Rahm Emanuel seek to swiftly and indefinitely create a system that functions in a fundamentally different manner across all aspects of society and government.

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10/8/09

Telemedicine: CMS definition and reimbursement guidelines

 Quoted directly from Centers for Medicare and Medicaid Services website:
Telemedicine

For purposes of Medicaid, telemedicine is the use of medical information exchanged from one site to another via electronic communications to improve a patient's health. Electronic communication means the use of interactive telecommunications equipment that includes, at a minimum, audio and video equipment permitting two-way, real time interactive communication between the patient, and the physician or practitioner at the distant site. Telemedicine is viewed as a cost-effective alternative to the more traditional face-to-face way of providing medical care (e.g., face-to-face consultations or examinations between provider and patient) that states may choose to cover. This definition is modeled on Medicare's definition of telehealth services located at 42 CFR 410.78. Note that the Federal Medicaid statute (Title XIX of the Social Security Act) does not recognize telemedicine as a distinct service.
Distant or Hub Site means the site at which the physician or other licensed practitioner delivering the service is located at the time the service is provided via telecommunications system.

Originating or Spoke site means the location of the Medicaid patient at the time the service being furnished via a telecommunications system occurs. Telepresenters may be needed to facilitate the delivery of this service.

Asynchronous or "Store and Forward" means transferring data from one site to another through the use of a camera or similar device that records (stores) an image that is sent (forwarded) via telecommunication to another site for consultation. Asynchronous or "store and forward" applications would not meet the above definition of telemedicine--see telehealth.
Reimbursement/Billing—Reimbursement for Medicaid covered services, including those with telemedicine applications, must satisfy federal requirements of efficiency, economy and quality of care. With this in mind, States are encouraged to use the flexibility inherent in federal law to create innovative payment methodologies for services that incorporate telemedicine technology. For example, States may reimburse the physician or other licensed practitioner at the distant site and reimburse a facility fee to the originating site. States can also reimburse any additional costs such as technical support, transmission charges, and equipment. These add-on costs can be incorporated into the fee-for-service rates or separately reimbursed as an administrative cost by the state. If they are separately billed and reimbursed, the costs must be linked to a covered Medicaid service. While telemedicine is not considered a distinct Medicaid service, any State wishing to cover/reimburse for telemedicine services should submit a State Plan Amendment to the Centers for Medicare and Medicaid Services for approval.
Medical Codes—States may select from a variety of HCPCS codes (T1014 and Q3014), CPT codes and modifiers (GT, U1-UD) in order to identify, track and reimburse for telemedicine services.

Telehealth (or Telemonitoring) is the use of telecommunications and information technology to provide access to health assessment, diagnosis, intervention, consultation, supervision and information across distance.

Telehealth includes such technologies as telephones, facsimile machines, electronic mail systems, and remote patient monitoring devices which are used to collect and transmit patient data for monitoring and interpretation. While they do not meet the Medicaid definition of telemedicine they are often considered under the broad umbrella of telehealth services. Even though such technologies are not considered "telemedicine," they may nevertheless be covered and reimbursed as part of a Medicaid coverable service under section 1905(a) of the Social Security Act such as laboratory service, x-ray service or physician services.
Other Considerations:
Medicaid guidelines require all providers to practice within the scope of their state practice act. Some States have enacted legislation which requires providers using telemedicine technology across state lines to have a valid state license in the state where the patient is located. Any such requirements or restrictions placed by the State are binding under current Medicaid rules. Medicare Conditions of Participation (COPs) applicable to settings such as long-term care facilities, and hospitals may also impact reimbursement for services provided via telemedicine technology. For instance, the Medicare COPs for long-term care facilities require physician visits at set intervals. Current regulations require that the physician must be physically present in the same room as the patient during the visit. This requirement must also be met for Medicaid to pay for services provided to Medicaid eligible patients while in a Medicare or Medicaid certified facility. Similarly, federal regulations require face-to-face visits for home health, and telemedicine cannot be used as a substitute for those visits. However, a telemedicine encounter may be used as a supplement to the required face-to-face visits.

Anyone eager to make a business out of remote care and telemedicine technologies must carefully read, re-read, and ultimately memorize the one-page guidelines above if they hope to remain a sustainable investment in the current environment. In my estimation, the most valuable by-product of a Billion-dollar US Connected Health sector will be its utility as a stimulant of hyper-innovation. Without a business plan and patient care protocols/procedures that achieve 75-100% reimbursement rates from CMS, any telemedicine program is doomed to be a money-pit regardless of the altruistic motives of its proponents. The entrepreneur who will emerge best-of-breed in telemedicine will be he/she who finds the shortest path to demonstrating "Meaningful Use" in the form of real improvement in patient outcomes.

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Telemedicine allows for long-distance diagnoses

HSG

Link: Telemedicine allows for long-distance diagnoses - The Washington Times.

As mentioned in an earlier post, 4 years ago Telemedicine was in its infancy, perhaps used for monitoring status of patients with pacemakers... Now, according to this article in the Washington Times, Dr. Kenneth Bird, a Harvard professor affiliated with Massachusetts General Hospital, innovated an approach to patient care using monitors and remote access to hospitals to examine, diagnose and treat his patients.

Also, according to the article, patients are wearing monitors that can be remotely tracked and physicians can be notified and/or paged when necessary. Telemedicine (a.k.a. Telehealth) is not a substitute for direct patient care, but rather, it is an augmentation to the existing delivery of care. That said, installation/implementation can be a huge expense (ranging between $2.5 and $3.5 million), so larger hospitals are more likely to implement remote monitoring.

The article continues with explanation of "concierge" medicine approaches, which are light years ahead of the status quo. The benefits to patients is purportedly rapid care from providers, from home or within a specialized, technology enabled facility.

It's an interesting thought, and another example of how technologies can be used to improve patient care if used appropriately. That said, there are likely significant privacy and security issues related to the "transaction" between patient and providers. For more information about HIPAA Requirements, The HIPAA Privacy Rule, The Security Rule, or The HITECH Act visit The Online HIPAA Survival Guide.

And, if you are interested in keeping current on the issues, sign up for the FREE HITECH/HIPAA Compliance Newsletter.

Courtesy of Healthcare & Technology Blog (By: Deborah Leyva): http://www.myhealthtechblog.com/2009/10/telemedicine-allows-for-long-distance-diagnoses.html

Telemedicine (Telehealth) is starting to get the attention it deserves, but innovation will not occur in a vacuum of unsustainable business models. Until self-sustainability for for telemedicine initiatives is achieved and replicated on a widespread basis it will not be as significant in the provision of care as it should be.

Posted via web from Connected Care Solutions