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Take Advantage of The CMS Telehealth Ruling Now!

Due to the current pandemic, the healthcare industry has not focused much on CMS's final physician fee schedule and telehealth expansion. The upcoming year provides a 10% pay decrease while expanding telehealth services. Health systems must shift their business models towards a "virtual first" mentality to improve the patient experience while aligning with the telehealth reimbursement model.

The key takeaway of the rule is that CMS finalized an expanded list of telehealth services, mostly temporarily. Make a bet as an organization that the allowable telehealth service will be a permanent care delivery feature. Health systems must redesign their operating model around the virtual model.


There is a final interim billing code for audio-only telehealth service after PHE (public health emergency) period. Emphasis should be on video visit transitioning away from audio-only telehealth. Providers must have the ability to see their patients while delivering the telehealth service visually.


Remote patient monitoring (RPM) is a game-changer as CMS finalized RPM clarifications requiring established patient relationship after the public health emergency (PHE) and permitting physicians and non-physicians to furnish RPM services. Four takeaways from the RPM rulings are:

  • Physicians and NPPs can provide RPM services.

  • RPM services can be delivered to patients with acute conditions as well as patients with chronic conditions.

  • Patient consent may be obtained at the time that the services are provided.

  • After the expiration of the PHE, an established patient-physician relationship must exist.


Virtual ED workflow must be part of your practice now, especially as health systems are looking to reduce their ED waiting time while creating access for the community. Does your organization have a separate virtual triage process using telehealth with the patient in the waiting area? A straightforward workflow is to establish a location for virtual triage where the patient is in the ER. The triage clinician is remote and working with the patient to establish whether the visit is an emergency or care delivered by the virtual clinician.

The biggest hurdle in establishing a virtual health model is ensuring that the patient population has internet connectivity. Health systems should help promote city programs like the one in Houston partnering with Comcast to provide internet vouchers for the community. It will also make sense for health systems to establish kiosk-like hardware access throughout the community so that patients can efficiently utilize telehealth services. Healthcare CIOs must focus their efforts on supporting and developing a "virtual first" strategy in 2021.





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