Since January, an 'S' code has been available to identify, and possibly bill for, telehealth services. CMS created it but does not recognize it, of course, on Medicare claims. Nevertheless, its existence means home healthcare agencies are able to introduce it to other payers, such as Managed Care Organizations and state Medicaid offices.
Here is the story of how S9110 came to be.
It begins with the longest-lasting demonstration project ever undertaken by CMS, a home telehealth demonstration project. Known as the Medicare Care Management for High-Cost Beneficiaries Demonstration, from 2006 through January, 2012, it developed evidence that an integrated telehealth and care management program can significantly reduce all-cause mortality in high-cost, high-risk Medicare beneficiaries with heart failure. The study was conducted in cooperation with Robert Bosch Healthcare, Inc. at Wenatchee Valley Medical Center in Wenatchee, Washington and Bend Memorial Clinic in Bend, Oregon.
The care management teams at both clinics used Bosch Healthcare's content-based remote patient monitoring system, Health Buddy, to communicate with patients, monitor vital-signs and support patient efforts to increase their knowledge about their chronic illness(es).
In commenting on the demonstration project's results, lead author of the study, Robert L. Page II, PharmD, MSPH, Associate Professor of Clinical Pharmacy at the University of Colorado School of Pharmacy, stated, "Over the past five years, integrated telemedicine programs have become an emerging tool to assist providers in the complex management of patients with heart failure...Our study found a significant reduction in mortality in patients with heart failure with the greatest benefit in those who actually engaged in the program. I believe that the key is motivating the patient to become engaged in their care." (emphasis added)
Dr. Page further explained the difference between telehealth systems that only measure and transmit patient vital signs and those that engage the patient in all aspects of their care, including signs, symptoms, health behaviors and knowledge of these health behaviors. The Health Buddy System used in this demonstration project added customized Q&A scripts and patient trainings, either on-screen or voiced, to the taking of vital signs.
In 2010, costs associated with HF were estimated to be $34.4 billion annually (direct and indirect costs). In 2006, Medicare beneficiaries with HF accounted for 37 percent of all Medicare spending and 50 percent of all inpatient hospital costs.
Retrospective Medicare claims data for HF beneficiaries enrolled in the CMHCB Demonstration (intervention group) were compared to control HF Medicare beneficiaries. HF was identified by ICD-9 codes and intervention and control beneficiaries were propensity-score matched using logistic regression. The program's effect on all-cause mortality over three years was estimated using Kaplan-Meier survival analysis and Cox proportional hazards models. Data for 623 matched pairs of Medicare HF beneficiaries were analyzed.
An abstract of the study can be accessed by clicking here.
Adding telehealth services to claims - Code S9110
Following the CMHCB demonstration project, Bosch Healthcare leveraged study results with its relationship with CMS and began to lobby for a policy change that would permit home health providers to add telehealth services to Medicare claims. In an online webinar this week, they described just how close they came.
The information that follows, while certainly valuable, is not to be taken as legal advice. Consult directly with each of your payers to determine how you might benefit from S9110.
According to Bill Broderick, North American Head of Marketing and Global Outcomes Research for Bosch Healthcare, and Caleb DesRosiers, JD, MPA, with the lobbying law firm Foley Hoag LLP, Bosch applied in January, 2012 for the creation of a HCPCS code that would be relevant to remote patient monitoring services and include conditions beyond CHF and patient education activities. CMS responded that there was not need for such a code.
Rather than take no for an answer, the Foley Hoag team consulted with and gained the support of several state Medicaid officials, then tapped Bosch Healthcare VP Karen Gilberg, MD, to re-present their case to the CMS HCPCS Workgroup in May of 2012. Finally, in November of that year, the workgroup granted the request and made S9110 available for use as of January of this year.
"See this as an opportunity to ask payers to update their policies and begin to offer reimbursement for technology-based remote services," urged Mr. DesRosiers. "It is possible to have a strong code set but still not have reimbursement. S9110 can be used by commercial payers and state agencies even though it is not recognized by CMS. But you must first have negotiated it into your insurance payer contract or have gotten your state legislature to allow Medicaid to use it for payment."
In the same petition, Bosch and Foley Hoag asked CMS to discontinue HCPCS code S9109, which narrowly defined telehealth and limited it to one disease state. "When the CMS HCPCS Workgroup agreed, we considered it a big win," DesRosiers continued. "Now there is a code that covers telemonitoring equipment rental, tele-scales, accompanying computer systems and software, telephone connections and device maintenance. S9110 allows payers to reimburse for these when submitted by Primary Care Physicians, hospitals, specialists, HHAs, SNFs and rural providers."
Medicaid has gotten on board
Once the purview of a handful of states such as Colorado, Kansas and New York, today all states permit or mandate reimbursement for telehealth services except Nevada, Tennessee, Ohio, New Jersey and Rhode Island. The explosion was fueled by the ACA, which made federal matching dollars available to states that incur telehealth reimbursement expenses. In 2014, those matching dollars will extend to the new insurance exchanges.
With the growth of Managed Care in Medicaid, look for increased acceptance of telehealth reimbursement among MCOs, regardless of state policy. Also, Medicare ACOs have the flexibility to cover remote monitoring as an extended benefit under their population management mandate. Even if it is not covered within a Fee For Service benefit, S9110 can at least be used to track monitoring use.
Case study: early S9110 example
An MCO named PriorityHealth decided to add the new S code to its coverage policy. When billing guidelines are met, the insurance company will reimburse for daily monitoring of weight, blood pressure and pulse. Guidelines say services must have prior authorization approved and on file; the agency must bill using form UB04; and claims must be sent monthly with revenue code 590 and HCPCS code S9110. They will also cover device install/de-install and expenses related to physician notification of clinical signs and symptoms.
Bosch Healthcare's Bill Broderick recommends that home healthcare providers continue to work with local ACOs to encourage them to offer better arrangements for telehealth service reimbursement. The company will work with its customers on this, using the results of the CMHCB Demonstration to help ACO officials understand the benefits. Bosch will also have a set of what it calls "Payer Engagement Toolkits" ready for distribution in a few weeks.
©2012 by Rowan Consulting Associates, Inc., Colorado Springs, CO. All rights reserved. This article originally appeared in Tim Rowan's Home Care Technology Report. homecaretechreport.com One copy may be printed for personal use; further reproduction by permission only. email@example.com