AHIMA’s Position
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. Health information (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. To expand access to care, reduce costs and improve convenience for patients using telehealth and remote patient monitoring technologies, AHIMA believes that public policy must:
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.
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.
Invest in telehealth infrastructure.
This includes 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.
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.
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.
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. To avoid increasing disparities, policy must identify and mitigate the underlying reasons why some groups have lower levels of use of telehealth services.
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.
Background
Telehealth involves “the use of electronic information and telecommunication technologies to support long-distance clinical health care, patient and professional health-related education, public health, and health administration.” Similarly, remote monitoring, a subset of telehealth, involves the collection, transmission, evaluation, and communication of patient health data from electronic devices. Telehealth offers the ability to connect patients to critical healthcare services using different devices (e.g.—smartphone, computer, tablet, monitoring device) and modalities (e.g.—video conference, remote monitoring, phone, and secure messaging). Today, 76 percent of US hospitals have partially or fully implemented telehealth services within their facility. However, widespread adoption of telehealth remains elusive due to a number of challenges including but not limited to limitations on coverage and payment of such services under Medicare. As policymakers consider expanding access to telehealth and remote patient monitoring services, AHIMA members have the expertise to offer insight.
To realize the benefits of telehealth, certain challenges must be addressed including:
Geographic and originating sites restrictions for telehealth services under Medicare.
Permanent removal of these restrictions from federal statute would enable providers to offer additional telehealth services outside of rural areas and enable patients to receive such services anywhere, including at home. This includes removal of the current limitations on types of services that can be provided via telehealth under Medicare.
Adequate reimbursement in the provision of telehealth services.
Expanding access to care using telehealth services requires consideration of the value telehealth provides and the related cost of delivery of services, including investment in the telehealth platform and other fixed costs related to the provision of telehealth services.
Such variability hinders the ability to analyze information in a consistent, standardized, and meaningful way across different payers. It also creates administrative burdens for providers and payers. New approaches will require consistent application of documentation requirements, coding and billing rules/guidelines, and quality measures across all payers.
New approaches will require access to reliable internet connections that support high-speed transmissions to take advantage of telehealth services.
Limited access to technological devices for telehealth services.
Consideration must be given to patients who may lack the knowledge or capacity to operate and troubleshoot audiovisual equipment, including patients that may have inexperience with technology or suffer physical and/or cognitive disabilities.
New approaches may require harmonization of state laws, regulations, and policies to expand the use and implementation of telehealth.
Protecting privacy and maintaining data security.
Expansion of access to care using telehealth services requires providers to continue to be good stewards of health information, including the collection, use, maintenance, and disclosure of such information. Appropriate and consistent privacy and security measures must also be in place to safeguard health information collected by telehealth technologies that may not be covered by the Health Insurance Portability and Accountability Act (HIPAA).
Telehealth has the potential to improve access to care for patients who have previously experienced challenges in accessing in-person care. New approaches require a better understanding of the exact barriers patients face to help guide implementation strategies so that all patients can effectively access telehealth services without compounding existing inequities.
January 5, 2021
AHIMA calls for the incoming administration to consider the implications of health information as they begin to implement new health policies in 2021.