- Although telehealth shows promise for driving more convenient patient care access, supporting that technology with effective care coordination and continuity will be essential to a quality patient experience, according to a recent comments letter from the American Academy of Family Physicians (AAFP).
AAFP wrote to comment on the 2020 Medicare Advantage and Part D Flexibility proposed rule that allows for greater flexibility in telehealth reimbursements. Specifically, the rules propose to allow MA plans to deliver additional telehealth benefits to patients starting in 2020. Additionally, the proposal allows greater flexibility to Part D plans for how they pay for telehealth.
Ideally, these rules would expand patient access to telehealth care, which in turn improves patients’ abilities to access treatment, said CMS Administrator Seema Verma following the proposal’s announcement.
“President Trump is committed to strengthening Medicare, and an increasing number of seniors are voting with their feet and choosing to receive their Medicare benefits through private plans in Medicare Advantage. Today’s proposed changes would give Medicare Advantage plans more flexibility to innovate in response to patients’ needs,” Verma explained in a statement. “I am especially excited about proposed changes to allow additional telehealth benefits, which will promote access to care in a more convenient and cost-effective manner for patients.”
AAFP offered support for these values, stating that “it is the policy of the AAFP to support expanded use of telehealth and telemedicine as an appropriate and efficient means of improving health when conducted within the context of appropriate standards of care,” wrote AAFP board chair Michael L. Munger, MD, FAAFP, who signed the letter.
However, the organization emphasized the importance of judicious telehealth use. While increasing the availability and use of telehealth is a step forward for patient care access, those efforts will be for naught if they do not include care coordination and other patient-centered strategies, Munger said.
“When considering utilization of telehealth services, it is important for patients to maintain a continuous relationship with their primary care physician for proper care coordination,” he explained. “Responsible care coordination is necessary to ensure patient safety and continuity of care for the immediate condition being treated, and it is necessary for effective longitudinal care. The most effective coordination is when the patient’s primary care physician or practice performs the telemedicine service.”
AAFP offered comments on three specific areas indicated by CMS.
First, the organization offered support of a CMS statute that would require an MA plan to offer an in-person option for certain benefits covered via telehealth.
“We support the statutory provision because we believe that the provision would improve MA enrollees’ access to telehealth within their homes,” Munger said on behalf of AAFP. “Plans would also have greater flexibility to offer clinically appropriate telehealth benefits that are not otherwise available to Medicare beneficiaries if this statutory requirement is effectively implemented.”
Second, AAFP commented on whether a provider delivering telehealth should count as a part of an MA plan’s network adequacy requirement. An MA plan’s network adequacy requirement pertains to the size and density of a covered network of providers for patients.
AAFP opposed such a regulation, noting the importance of providers delivering in-person care. In-person care is essential for care coordination and a positive patient experience, regardless of the care access benefits that come with telehealth.
“If a provider is only available to provide care virtually, then they are not truly ‘available’ to meet all potential care needs for a patient in the payer’s network within the applicable medical specialty,” Munger pointed out. “The AAFP urges CMS to protect Medicare Advantage beneficiaries from an encroachment of direct-to-consumer telemedicine not coordinated with the beneficiaries’ usual source of primary care.”
Providers who deliver both in-person and telehealth care may count toward an MA plan’s network adequacy requirement, Munger stated.
Finally, AAFP responded to a CMS query about next steps for implementing telehealth in MA plans. Munger explained the importance of emphasizing care coordination with a primary care provider within telehealth models, stating that this should be the bedrock of further MA innovation.
“As discussed earlier, responsible care coordination is necessary, and the most effective coordination is when the patient’s primary care physician or practice performs the telemedicine service,” Munger concluded. “It must also be noted that forwarding documentation by electronic means, including fax, is not acceptable for coordination of care with the primary care physician or medical home.”