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Medicare COVID-19 Telemedicine Factsheet

The COVID-19 outbreak has not only disrupted daily life across the globe, but the contemporary healthcare model as well, with an urgently needed shift to digital medical solutions. Federal regulations are changing continuously, insurance coverage has greatly expanded, and the use of telemedicine is growing at a tremendous rate assisted by new policies and a widespread loosening of restrictions previously impeding access to care.

As part of the battle against the novel coronavirus pandemic, the Centers for Medicare & Medicaid Services (CMS) have expanded access to Medicare telehealth services on a temporary and emergency basis and lessened HIPAA enforcement effective as of March 6, 2020. These updates offer Medicare beneficiaries – many of whom are at an increased risk for serious COVID-19 illness – a safe, alternative model of care in the form of a wider range of remote services. During the COVID-19 crisis, innovative uses of telemedicine technology are driving routine care, keeping vulnerable demographics safe, and expanding access to health care. 

“The benefits are part of the broader effort by CMS and the White House Task Force to ensure that all Americans – particularly those at high-risk of complications from the virus that causes the disease COVID-19  – are aware of easy-to-use, accessible benefits that can help keep them healthy while helping to contain the community spread of this virus,” a statement from the CMS on the promotion of telemedicine reads. Further information about the newly implemented guidelines for patient care and their implications on telehealth services during the COVID-19 outbreak are outlined below.

Expansion of Telehealth Services

1135 Waiver

As part of the program, the 1135 waiver was introduced to lessen prior restrictions and promote wider access to remote care. Prior to the waiver, Medicare was only able to pay for telehealth on a limited basis, for example, when a patient was receiving care in a designated rural area or when received the service in a healthcare facility. Under this waiver, the following changes have taken effect:

•   Office, hospital, and other telehealth visits will now be covered and reimbursed for the same amount as an in-person visit.
•   A wide range of providers can offer telehealth services across the nation, including nurse practitioners, psychologists, and licensed social workers.
•   Medicare beneficiaries are now be able to receive a wider variety of services through telemedicine – such as evaluation and management visits, mental health counseling, and preventative health screenings.
•   The HHS Office of Inspector General is providing flexibility for healthcare providers to reduce or waive cost-sharing for telehealth visits paid by federal healthcare programs during this time.

Virtual Services 

Medical professionals can provide their Medicare patients with a range of virtual services as part of the telehealth program, including Medicare telehealth visits, virtual check-ins, and e-visits. Specific requirements for each service are outlined below.

Medicare Telehealth Visits

Throughout the course of the COVID-19 outbreak, Medicare patients may use digital technology for office, hospital visits, and other services previously rendered in-person. The recent changes include:

•   A wider range of practitioners is now able to get payment covered for telemedicine services – including physicians, nurse practitioners, physician assistants, midwives, anesthetists, psychologists, clinical social workers, registered dietitians, as well as nutritional professionals.
•   Virtual visits will now be paid at the same rate as regular, in-person visits.
•   Providers must use an interactive audio and video system permitting real-time communication during Medicare telehealth visits in order to be reimbursed appropriately.
•   New CMS guidelines remove the requirement of an established patient-provider relationship for the duration of the public health emergency, further details below.

“The Department of Health and Human Services (HHS) is announcing a policy of enforcement discretion for Medicare telehealth services furnished pursuant to the waiver under section 1135(b)(8) of the Act.  To the extent the waiver (section 1135(g)(3)) requires that the patient have a prior established relationship with a particular practitioner, HHS will not conduct audits to ensure that such a prior relationship existed for claims submitted during this public health emergency,” the CMS statement reads.

Virtual Check-ins

In all areas of the country, Medicare beneficiaries will be able to have brief online check-ins with practitioners – or brief communication technology-based services. Policy changes related to this include:

•   Medicare will now pay for virtual check-ins for patients with established relationships with their physicians to prevent unnecessary travel and office visits.
•   Brief virtual check-ins can be conducted using a broader range of communication methods than Medicare telehealth visits; medical practitioners may bill for virtual check-in services provided via several telecommunication technologies – including telephone, audio/video, secure text messaging, email, and patient portals.
•   Services cannot be related to a medical visit within the previous 7 days or lead to a medical visit within the following 24 hours, or the soonest available appointment.
•   Patients must verbally consent to receive virtual check-in services.
•   Patients can submit video/images using store and forward methods to be interpreted by physicians within 24 business hours.


As part of the updated guidelines, established Medicare patients in all types of locations can have non-face-to-face patient-initiated communications with their providers using online patient portals. These services can only be rendered in accordance with the following guidelines:

•   E-visit services can only be reported to Medicare if the billing practice has an established relationship with the patient.
•   E-visits must be initiated by the patient although, practices may educate patients on the availability of these services prior to their initiation.
•   Communications can occur over a 7-day period and only after the patient provides verbal consent to receive telehealth services.
•   These services may be billed using CPT codes 99421-99423 and HCPCS codes G2061.
More information on relevant billing codes for e-visits and other virtual care services can be found on the CMS’ website.

Health Insurance Portability and Accountability Act (HIPAA) Updates 

In addition to the amendments above, the HHS Office for Civil Rights will lessen restrictions and waive penalties in association with HIPAA compliance for health care providers that serve patients in good faith through virtual communication technologies during the COVID-19 outbreak. More information on the latest HIPAA updates can be accessed here.

Although Medicare already offers flexibility to states that wish to implement telehealth services, the most recent developments signal a major step forward in the direction of telemedicine, despite the temporary nature of federal guidelines. With the help of changes in regulations and the strategic expansion of telehealth, patients can now reach providers easily via a range of tele communication options from the comfort and safety of their homes, while medical professionals can readily provide care without reimbursement concerns. As the COVID-19 public health emergency continues to evolve rapidly, regulations and guidelines may change; clinicians are encouraged to stay up-to-date on the latest medical guidance.

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Choosing the Right Telemedicine Provider for Your Practice

Recent changes to the practice of medicine are evident; no longer are patients coming in for routine appointments, follow-up visits, or elective procedures. Many patients and practitioners are opting for the use digital health services, while some individuals are refusing to seek needed care out of virus-spurred fears. Alongside a marked decrease in demand for in-person care has been a significant rise in telemedicine use – the number of online visits in March surged by up to 50% per data from Frost and Sullivan consultants.

With the widespread adoption of telemedicine, healthcare market analysts now anticipate to see the general number of medical care visits rise above 200 million – up from the 36 million predicted for 2020 – and estimate all virtual health encounters will surpass 1 billion by the end of the year.

A multitude of software developers has already begun capitalizing on the occasion by developing new technological solutions and telecommunication platforms to fulfill the rising demand for online medical services. Meanwhile, to ease the implementation of telehealth across specialties, federal regulations have been amended relaxing HIPAA enforcement rules, mitigating reimbursement barriers, and making other helpful policy changes. However, the widespread lessening of restrictions has also prompted cybersecurity concerns as a result of an increasing number of users sharing their protected health information and personal data online. Due to time constraints and a rushed speed of market entry, many of these novel software solutions are lacking in safety certifications and robust testing.

Changes in Telemedicine Regulations

Now that the U.S. Department of Health & Human Services’ guidance allows HIPAA-covered entities to “use any non-public facing remote communication product that is available to communicate with patients,” providers are turning to common audio or video communication technologies. Broadening access to remote care, the agency now permits providers the use of programs such as Apple’s FaceTime, Facebook’s Messenger video, and Skype. The agency notes, however, that patients should be made aware of the potential cybersecurity and data privacy risks associated with these platforms as they are not intended for telehealth-specific use.

“This exercise of discretion applies to telehealth provided for any reason, regardless of whether the telehealth service is related to the diagnosis and treatment of health conditions related to COVID-19,” the HHS outlined in a statement.

Evaluating Telemedicine Providers

Faced with a seemingly abundant amount of telehealth vendors, healthcare providers may find it difficult to determine which one will best fulfill the needs of their practice. Many may already have embedded telehealth functionality via their electronic health record (EHR) vendors or their employing organization; these solutions can allow for seamless integration into practice, be cost-saving, and tend to have proven safety records. For practitioners seeking new telehealth vendors, the selection process may be daunting although the steps outlined below can help navigate the crowded landscape of telemedicine providers.

Finding and Understanding Your Options

In beginning the search for a telehealth provider, physicians should focus on narrowing down the possible options by outlining their practice’s key criteria and goals. The evaluation of potential vendors must take into account these values and should focus on the perspective of a long-term partnership, not just that of a transactional business. The goal of integrating a telehealth provider into your practice is to develop a long-standing relationship with them in order to have an expert resource on hand, guaranteed support throughout the introduction process and beyond, as well as a reliable, secure platform for your patients.

Researching potential telehealth services and their reviews is a critical component of selecting a vendor, however, it may be challenging to choose from the 900+ platforms available. Asking for word-of-mouth referrals and recommendations from your professional network can often help narrow down a list of possible telehealth vendors. Practices can also consider consulting the American Telemedicine Association or their state medical association for further suggestions.

After sufficient research, medical providers should select a shortlist of a few quality vendors and schedule calls with each one to discuss their service offering, policies, and compliance with stat guidelines. It is also important to incorporate legal feedback and security standards when evaluating potential partners to assure any potential liabilities are minimized.

Finally, upon selecting a few prospective vendor candidates, practitioners should develop a Request for Proposal (RFP) that clearly outlines their goals and share it with the vendors that best align with them.


Getting to Know the Platform and Team

After receiving and reviewing RFP responses, providers and medical practices should ask telehealth vendors for case studies and referrals to determine whether they can be considered safe, reputable sources. Scheduling time to speak with product engineers and existing customers can help physicians obtain a more realistic understanding of how the platform could function in their daily practice.

The next important part of the selection process is familiarizing yourself with the platform itself as well as the vendor’s customer service team – which you will be primarily communicating with. To do this, healthcare providers should schedule live demos of the software and informational calls with the vendor team. During these interactions, physicians should focus on evaluating the software across the six key factors outlined below in order to determine whether the service will adequately address their practice’s needs.

Six Key Factors for Evaluation


Important aspects of the vendor’s business to keep in mind include: tenure, funding source, financial stability, notable customers, and other affiliations. Practitioners are also encouraged to consider the company’s business model, product cost, reimbursement rates, risk sharing, and payment program options to approximate their return on investment. Does the vendor have expertise in offering telehealth to other practices in your specialty? Are they aware of federal and private insurance requirements? These are also questions to assess while investigating potential vendors.

Information Technology

From a technical perspective, the ability of the program to be integrated within a practice’s current IT landscape – and the EHR system in particular – can have a significant impact on decision making. As does the cost, process, and timeline of implementation, all of which are important factors to consider in the current environment. Other valuable considerations include: patient geolocation for licensure requirements, patient access to data, customization capabilities, biometrics/RPM integration capabilities, and the impact of regular use on internet and local network usage.


With cybersecurity threats currently at an all-time high, security guarantees offered by telehealth vendors are paramount. In evaluating a potential telemedicine provider, physicians should ensure it complies with HIPAA and local regulations, has a clear liability structure in place for managing potential data breaches, and is transparent about its data use practices. Other important security factors include user authentication and authorization systems and whether it has in-platform patient consent capabilities.


The usability of the product itself is one of the most essential factors for consideration in choosing a telehealth vendor. During live demos, healthcare providers should note their personal reflections on user experience – will it be easy to use for other care team members and patients? How long does it take for the platform to launch? How many steps are required to launch the application? Other factors for consideration here are: dashboard/workflow assimilation, multi-specialty application, patient and care team engagement metrics, as well as billing and payout processes.

Customer Service

Another key variable to evaluate when selecting a telemedicine provider is the quality of the company’s customer service. Medical practices and professionals should consider the level of support that would be available to them during and after service integration, which can include staff training, patient education, project, management, data analysis, and many other practice-enhancing features. In addition, the vendor should be able to provide an adequate degree of technical support for patients who may need assistance with setting up the platform, accessing it from different devices, and troubleshooting IT issues.

Clinical Validation

The final factor healthcare practitioners should guarantee is the clinical validation of their chosen telehealth technology; this can be done by requesting any available documented clinical outcomes as well as published peer-reviewed research.

Test the Product

After selecting a telemedicine solution that best suits their medical practice, healthcare professionals are urged to test the technology with either a patient advocate, member of a patient advisory board, or other staff member to ensure it can be successfully implemented. Some platforms and services may prove to be too complicated for patients to use, requiring more time spent on training and technical assistance rather than offering an efficient method of digital care delivery.


Setting your practice up for success in the digital space requires careful consideration of a variety of factors, most notably the 6 key conditions outlined above. In addition, selections of telehealth vendors must be made in accordance with state and federal regulations; medical offices and health organizations can consult practices on the requirements and help them narrow down available options. Furthermore, risk and liability mitigation is essential to a safe online practice – clinicians are encouraged to incorporate legal feedback and cybersecurity best practices to mediate any potential threats.

To further assist practices and providers in determining which telemedicine service is right for them, Healthcare IT News has published an ongoing list of telehealth vendors and their service offerings, accessible here.

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Physician’s Recession Guide: How to Protect Your Practice During COVID-19

Medical practices managing patients during the COVID-19 pandemic are being confronted with new and unique operational challenges as many have turned to telemedicine, bringing their services online to continue patient care. Other providers may find it increasingly difficult to continue conducting business in light of wide-scale cancellations of elective procedures and recommendations against in-person office appointments. Unprecedented economic fallout related to the virus outbreak is proving to be another significant concern facing the healthcare system.

In response to this complex issue faced by clinicians across the country, the American Medical Association has compiled a set of recommendations and guidelines on handling the financial and operational repercussions of the outbreak for practice owners and office administrators.

To better adapt practices to current demands and protect them from adverse financial impact at this time, medical professionals should consider the following important variables and strategic responses:

Insurance Coverage 

A critical first step to securing the medical practice is to ensure it is protected against COVID-19 related liabilities under business insurance policies. Whether the protection is part of insurance policies will determine the associated risks and help providers make vital business and operational decisions. Experts urge practices to contact their insurance brokers to obtain a complete copy of all insurance policies, understand government emergency orders and decrees, as well as to track losses and expenses incurred during this time for future claims.

Further, practitioners are urged to consult legal counsel for explanations of how they can exercise existing policies and how government orders impact business operations in their state. “You may need to notify professional liability carriers in the event practice providers are called upon to assist with emergency care, including outside of their normal clinical service arrangements,” the AMA adds in its latest guidelines.

In addition, the U.S. Department of Health and Human Services has published a declaration of liability protection against certain medical countermeasures related to COVID-19 which can be accessed here. 

Financial Obligations and Contingency Planning

To minimize potential economic risk, practices are encouraged to revise financial plans at this time and ensure their ongoing liquidity; this will hopefully protect those businesses suffering from a loss of clinical revenue due to cancelled procedures, decreasing outpatient visits, and partial or whole closures. It is recommended practices develop a financial contingency plan based on minimum cash flows needed to remain in operation, review existing loan documents and financial covenants, and determine if slowdown of business could trigger a default situation.

Practices should prioritize managing cash to the best extent possible and consider delaying payments of discretionary bonuses as well as other such payments. They may also choose to consider requesting forbearance, forgiveness, or a standstill from lenders and other creditors. Proactive communication with these third-parties can help ensure accommodations are granted during revenue disruptions.

Additionally, clinicians are urged to monitor resources as they become available concerning economic relief packages for business and workers affected by the outbreak; the U.S. Small Business Administration has already begun introducing low-interest loans while other organizations – such as United Way – have created COVID-19 relief funds to provide additional funding.

Current and Future Supply Needs 

In light of global shortages of essential medical supplies, such as personal protective equipment and respirators, practices are encouraged to evaluate their current and future supply needs. While a reduction in in-person office visits may decrease the number of interactions requiring the use of such equipment, practices should determine how much cash flow can be devoted to stocking up on essential supplies for the forthcoming months.

“While your business may be interrupted, you may also be called upon to triage patients outside of your normal workflow, so contact your supply vendors and, if necessary, your state and local health authorities to ensure that you are in the queue to receive necessary supplies,” the AMA recommends.

Continuing Business Operations 

A growing number of “shelter in place” orders and their extensions may impact the ability of medical practices to continue business operations. However, many of these orders designate healthcare services as essential businesses but publicly available guidance may remain unclear. Practitioners are urged to consult with local counsel to determine the implications of executive orders and how to apply them to their practice.

To further assist clinicians, the AMA provides two non-jurisdiction specific template letters that can be modified to suit the needs of each practice in COVID-19 related circumstances. These templates aim to function as a resource for providers who may encounter questions from authorities or resistance from employees who may not report to work due to “shelter in place” orders.

Regular Communication with Patients

Whether a practice is operating normally or offering digital medical services, it is currently essential to maintain regular communication with patients – in particular, those who may be at-risk of adverse health outcomes as a result of the disruption in healthcare. Reports reveal a silent sub-epidemic caused by COVID-19, that of an increasing number of patients forgoing needed medical care out of fear of contracting the virus in a hospital or medical facility. Patients need to be made aware of the COVID-19 prevention and safety protocols enforced at a practice or other healthcare center and be encouraged to stay in contact with their physicians via telehealth and to come in for in-person care when needed.

Administrative Resources

Despite interruptions in operations, many practices will still operate remotely. To assist healthcare providers in meeting immediate care needs while working from home, office administrators are encouraged to compile essential resources outlining best telemedicine practices. This includes putting in place methods of maintaining documentation protocols to obtain payments, including processes for collection of accounts, claims submissions, and other activities. More information regarding medical codes and scenario planning has been made available as part of the AMA’s resource hub.

Workflow and Digital Health Tools 

To protect staff members, conserve valuable equipment and supplies, and reduce the safety and liability risk to your practice, providers are urged to follow the latest guidance issued by governmental agencies when reviewing scheduled visits and choosing which appointments to postpone, cancel, or proceed with as usual.

Digital tools can assist providers by allowing them to continue conducting business remotely via telehealth services and remote patient monitoring. Following the CMS’ telemedicine toolkit can help physicians and practices utilize these technologies during the COVID-19 outbreak and provide insight into emerging policy changes and practice flexibilities.

 Employee Management 

Keeping employees updated and informed is essential to managing concerns about health and safety. Practices are encouraged to institute interim guidelines that aim to educate their employees, including outlining circumstances under which they should not report to work, contact information for relevant resources, and specify leave policies related to COVID-19.

Depending on revenue and cash flow challenges, practices may need to furlough or terminate non-essential employees. In these cases, practices should seek legal counsel to understand their obligations, requirements regarding communication of employment status, and identify workflow changes which may be necessary at this time.

While all practices may not be able to sustain each of their employees, healthcare staff is urgently needed at medical facilities across the nation – as such, administrators should identify external opportunities for their furloughed or terminated staff members when possible.

The CDC has issued interim guidance to assist business and employers in navigating the evolving situation, while the U.S. Department of Labor also released resources pertaining to employee furloughs and unemployment benefits.

The COVID-19 pandemic has prompted unprecedented policy and regulatory changes affecting the healthcare system nationwide; it is essential for medical professionals to stay current on the latest developments in requirements and afforded flexibilities. As the COVID-19 outbreak continues to evolve, federal guidance and relief efforts are forecasted to offer further support for front-line workers as well as those physicians whose practice has been affected by the pandemic. To access the latest recommendations for practices and physicians navigating patient care at this time, visit our COVID-19 Resource Hub.

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