By Bert Orlov, Director, EisnerAmper’s Health Care Consulting Group
Telehealth has become a material element in the care delivery landscape, and many providers have ramped up quickly to meet the immediate practical need. The entire industry is now at a crossroads as providers begin returning to full schedules and elective procedures. They must either optimize their makeshift processes or develop new platforms to respond to what will likely be substantial and sustained demand for these services.
Practices that have already started telehealth services should reassess to ensure they are ready for potential rule changes after the pandemic eases. They should also leverage their newfound skills to expand market share and profitability. Practices that have not yet materially entered the telehealth market must move swiftly to establish a presence, at least with their own patient base, but optimally with a larger universe for specialty consults or non-local markets. In either context, telehealth success depends on these six critical steps:
- Market Targeting
- Scheduling and Operations Flows
- Revenue Cycle Management
- Patient Service Management
1. Market Targeting
Most practices have focused on select services delivered to their own patients. This constitutes their base, but more opportunity may exist. Look into whether there are more services your practice could deliver via telehealth and if there are larger patient populations to reach.
To optimize opportunity within your own patient base requires a full understanding of services allowed by the payor, your patient profiles (both clinical needs and payor mix), and your capabilities. Consider:
- If you can support urgent care visits with telehealth.
- If you could conduct more tele-monitoring—such as BP, glucose or weight—supported by appropriate tools.
- How you can redesign therapeutic services (e.g., PT) for remote delivery.
- If you have particular expertise, explore direct-to-consumer services or collaboration with referring practices or under-served regions or specialties.
2. Scheduling and Operations Flows
Typically, practices function on in-person appointments, but telehealth requires different scheduling and operations flows. In particular, a practice needs to determine:
- Which providers deliver telehealth visits and when.
- How telehealth visits fit into a given provider’s schedule and/or the practice’s array of providers.
- How the practice should manage provider punctuality or create policies for callbacks.
- Which new procedures are required for check-in/check-out, including insurance verification and copay collection.
While these operational issues may seem straightforward conceptually, practices will need to completely reinvent their scheduling process and rethink how both staff and providers organize their days.
During the pandemic, government and commercial payors relaxed HIPAA rules around protection of personal health information (PHI). As COVID-19 recedes, more stringency will likely return requiring:
- A credible, secure electronic platform.
- Demonstrable efforts around tracking to ensure information protection.
- Information integration into practice management and electronic medical records (EMR).
Identifying the optimal system—based on price, complexity and interoperability—requires investment as does the integration of that system with scheduling and operations flows (see above). Finally, you will need to train both providers and administrative staff on these tools.
4. Revenue Cycle Management (RCM)
Critical to all practices is collecting money for services provided. Telehealth has some distinct characteristics for which providers, and especially RCM staff, need to develop skills. For example, the practice will need to:
- Understand clearly which payors authorize which telehealth services and conduct scheduling accordingly to avoid providing non-covered services.
- Define when and how patient insurance/demographic data will be collected and who is responsible.
- Ensure appropriate training for coding (see below) for both providers and billing staff.
- Focus tracking efforts on payor response to submission of telehealth visits and addressing issues as they arise, which may change over time.
- Manage collections of copays and so forth, which is already challenging when a patient presents in person, let alone remotely.
The above represents just a small subset of challenges that arise when adapting standard RCM practices to telehealth.
Federal authorities and commercial payors report grave concerns about the potential for fraud in telehealth. As such, practices should be prepared for more aggressive auditing of telehealth. To ensure that your practice is not exposed to risks upon audit, you should:
- Know the coding, both CPTs/HCPCS and ICD-10s, with strong training for providers and revenue cycle staff, including routine updates on the changing environment.
- Document rigorously to demonstrate compliance.
- Develop recordkeeping to show that actual patients received actual services.
For those who have already delivered material volumes of telehealth services, conduct a retrospective review of charts to ensure that patterns which have begun to take root are positive.
6. Patient Service Management
Because of a lower level of personal patient engagement, extra effort will be required to sustain patient relationships. Dissatisfaction may be harder to identify, since patients will not have immediate access to management to address complaints. Scheduling follow-up visits and procedures/surgeries will require new approaches for staff to follow, since the patient will not be in the office and not so easily directed to the appropriate staff to set appointments. Furthermore, for value-based contracting that measures patient service, new standards and methods may be required.
These are challenging times for the industry as a whole, but taken step by step, they can be overcome to the betterment of your practice.