In response to legislation recently passed by Congress, the American Academy of Neurology (AAN) offers room for further improvement on changed policies and recommendations made by neurologists for their patients. The Coronavirus Preparedness and Response Supplemental Appropriations Act of 2020 (the Act) permits the Secretary of Health and Human Services (HHS) to waive existing restrictions on the use of telehealth for Medicare beneficiaries during the COVID-19 outbreak.
Specifically, the AAN supports that for the duration of the emergency:
• telehealth visits be paid at the same rate as in-person visits,
• Medicare pay for professional services furnished to beneficiaries in all areas of the country in all settings, unrestricted by diagnosis,
• Medicare pay for telehealth services furnished to beneficiaries in any healthcare facility and in their home,
• providers can deliver care from their homes as the Administration has waived the requirement that the originating site must be a physician’s office or other authorized healthcare facility
Individuals with neurologic conditions still need access to high-quality neurology care but may not be willing or able to visit their neurologist in-person during the outbreak. Lapses in care can lead to increases in adverse events, which may lead to increased utilization of otherwise avoidable emergency care and face-to-face services. With the expanded availability of telehealth services, the AAN anticipates that providers will work to rapidly develop new telehealth capabilities within their practice. As such, the AAN urges HHS promote to providers the availability of new telehealth options. The HHS should also develop and disseminate guidance that addresses the regulatory, billing, compliance, privacy, and other legal considerations associated with providing telehealth services.
The AAN recommends that HHS should allow existing telehealth companies to provide, without charge during the emergency, telehealth technology and education to providers who do not currently use telehealth in their practices. The AAN notes that doing so may have implications for certain provisions of the AntiKickback Statute.
The AAN recommends that states that have not already done so, enact payment and coverage parity requirements for commercial payers to ensure that medically necessary and clinically appropriate care can be delivered via telehealth at rates for in-network providers for that are not lower than the rates paid for services delivered via in-person methods.
The AAN urges the HHS to give providers relief from administrative burdens, whenever possible, throughout this crisis so that providers can focus on delivering care to individuals over administrative requirements and paperwork.
The AAN has also provided a COVID-19 Neurology Resource Center that has a list of articles consisting information about COVID-19 and a registration for a free Webinar on March 26, 2020. The Webinar is featuring best practices on implementing telemedicine services and updates on changing US regulations during the novel coronavirus Public Health Emergency.
Audrius V. Plioplys, MD
Brad Klein, MD, MBA, FAAN, FAHS, FAANEM, and Raissa Villanueva MD, MPH, FAAN
Michael S. Cartwright, MD, MS, and Hwajin Lee, MD