AHIMA Public Policy Statement on Telehealth

There is no question that the COVID-19 pandemic played a catalytic role in the use of telehealth in 2020. A recent survey by Rock Health and Stanford Medicine found an increased use of live video telehealth, with 43 percent of respondents reporting that they had a video visit (compared to 32 percent in 2019).

Much of the increased use of telehealth in the US has been the result of steps taken by the Centers for Medicare and Medicaid Services (CMS) to expand telehealth services for Medicare beneficiaries. At the same time, the US Department of Health and Human Services’ Office for Civil Rights took steps to exercise its enforcement authority and waive penalties against providers from HIPAA violations who in good faith used applications that allow for video chats during the public health emergency.

One year since the start of the pandemic, the question isn’t “will telehealth go away?” but rather “how do we ensure its eventuality?”

Ongoing debate about the future of telehealth is currently happening in the halls of Congress, within federal agencies, and in state legislatures as much of the fate of telehealth in the US is contingent upon policymakers at the state and federal level.

To ensure the health information (HI) perspective is a part of these discussions, AHIMA’s Board of Directors recently approved a public policy statement on telehealth and remote patient monitoring.

By approving this statement, the board affirmed its belief that “AHIMA supports the use of public policy and other tools to expand access to care, reduce costs, and improve convenience for patients by using telehealth and remote patient monitoring technologies and that HI professionals have considerable knowledge and relevant experience to contribute in developing public policy that seeks to expand telehealth while ensuring the continuity of accurate, timely, and trusted health information.”

The public policy statement identifies seven considerations for policymakers to expand the use of telehealth:

1. Promote patient and provider choice. Policy must ensure that patients and providers are not arbitrarily limited by geography or modality when receiving or offering telehealth services. Policy must also ensure that patients have access to telehealth services anywhere, including at home. Additionally, policy must encourage all technologies and/or modes of telehealth, provided the technology is safe, effective, appropriate, secure, interoperable, and can be integrated into a provider’s clinical workflow.
2. Ensure parity between telehealth services and in-person services. Policy must treat remote services no differently than services provided to patients in-person in terms of the scope of services that can be provided. Policy must also ensure that reimbursement of telehealth services is commensurate with the expense of providing such services, including investment in technology related to telehealth services. Additionally, policy must ensure equivalent documentation requirements, coding and billing rules/guidelines, and quality measures are consistently applied across all payers for telehealth services.
3. Invest in telehealth infrastructure, including broadband internet access in rural and underserved communities (in both urban and rural areas) that have limited access to affordable and adequate connectivity, hampering their ability to deploy telehealth solutions.
4. Prioritize privacy and security. Efforts to expand the use of telehealth requires consideration of appropriate privacy and security policies, including consent management and limits on the collection, use and disclosure of health information to that which is minimally necessary to the specific transaction in question. This also includes consideration of identity management and data storage and retention practices. Additionally, policy must consider the implementation of appropriate and consistent security safeguards for telehealth platforms, such as authentication and data encryption.
5. Facilitate the delivery of healthcare services across state lines. Policy barriers that deter patients from seeking treatment across state lines using telehealth services may lead to fragmented or delayed care. Policy must encourage interstate licensure compacts and other licensure portability policies that enable clinicians to deliver care across state lines using telehealth services.
6. Address disparities in the use and willingness to use telehealth and remote patient monitoring technologies. Telehealth offers the potential to improve access to care and address disparities in underserved communities. However, evidence suggests that inequities exist in accessing telehealth services on the basis of age, gender, race/ethnicity, language, geography, and income.^1,2 To avoid increasing disparities, policy must identify and mitigate the underlying reasons why some groups have lower levels of use of telehealth services.
7. Promote program integrity. At the same time that public policy expands access to telehealth, it must also ensure appropriate guardrails and oversight are in place to prevent opportunities for fraud and abuse, including new approaches that monitor and audit unusual billing behaviors related to telehealth.

To develop this statement, AHIMA brought together an AHIMA member work group on telehealth not only to better understand the opportunities and challenges of expanding telehealth but to ensure that the principles were reflective of the operational realities of today.

Federal lawmakers will continue to grapple with questions over the future of telehealth this year. Most recently, the US House Energy and Commerce Committee held a hearing about the future of telehealth—the first of many anticipated hearings about this topic. Congress’ Medicare advisory panel (MedPAC) also recently called for a one- to two- year extension of existing telehealth expansion to gather more evidence about the impact of telehealth on access, quality, and costs to help inform more permanent changes. While the fate of some of these discussions is still unclear, AHIMA and its members will bring their expertise to the table as these debates continue.

Work Group Members

• Brenda K. Beckham, RHIA, executive director of HIM, Baptist Health (board member)
• Lesley Clack, ScD, CPH, assistant professor and MHA program coordinator, health policy and management, University of Georgia
• Penny Crow, MS, RHIA, SHRM-SCP, principal/compliance officer, Brittain-Kalish Group, LLC
• Jennifer Garvin, PhD, MBA, RHIA, CTR, CPHQ, CCS, FAHIMA, division director and associate professor, the Ohio State University College of Medicine
• Faith McNicholas, RHIT, CPC, CPCD, PCS, CDC, manager, coding and reimbursement, advocacy and policy, American Academy of Dermatology
• Jeanne Solberg, MA, RHIA, FAHIMA, health information consultant
• Sarah Throop, CCS-P, coding quality expert, Indiana University Health

Notes

1. Eberly, Lauren A., Sameed Ahmed M. Khatana, Ashwin S. Nathan, et al. “Telemedicine Outpatient Cardiovascular Care During the COVID-19 Pandemic.” Circulation. June 2020. https://www.ahajournals.org/doi/10.1161/CIRCULATIONAHA.120.048185.
2. Eberly, Lauren A., Kallan, Michael J., Julien, Howard M., et al. “Patient Characteristics Associated With Telemedicine Access for Primary and Specialty Ambulatory Care During the COVID-19 Pandemic.” JAMA Network Open. December 29, 2020. https://jamanetwork.com/journals/jamanetworkopen/fullarticle/2774488.

Lauren Riplinger (lauren.riplinger@ahima.org) is vice president of policy and government affairs at AHIMA.