The expansion of telehealth is changing the landscape of health care. This is the final installment in a four-part series exploring what providers should know about this growing area.
There are many business models and provider arrangements for the provision of telehealth. Given the regulatory climate and increasing use of telehealth by health care providers and patients, these business models and provider arrangements are continuing to change.
Health care providers should think about how telehealth is provided pursuant to the model and provider arrangements to ensure regulatory compliance, proper documentation, and the ability to receive reimbursement for the provision of telehealth. The following are just a few examples of telehealth models and provider arrangements:
- Chronic care management – Pain management clinic contracts with a physician practice group for chronic care management and follow-up services.
- Online patient access/portals/technical support – A sleep disorder center provides patients with online access to view results from the polysomnography (sleep study) and offers patients options regarding the treatment of sleep disorders.
- eHealth, mHealth, and medical apps – Self-tracking apps for diagnostics, care support, and monitoring that may include weight loss, smoking cessation, medication compliance, and durable medical equipment compliance.
Health care providers should carefully consider and monitor the structure of business models and provider arrangements so that the facility and health care providers are properly documenting the provision of the telehealth and receiving the correct reimbursement. Health care providers should consider the following issues related to the provision of telehealth:
- Business terms and transactional considerations, including compensation;
- Intellectual property;
- FDA compliance;
- Data access;
- Scope of practice and licensure;
- Patient privacy and information security;
- Fraud and abuse concerns;
- Cybersecurity insurance;
- Reimbursement; and
- Regulatory compliance, including HIPAA and state privacy regulations.
As telehealth continues to grow, health care providers and patients will need to navigate telehealth requirements for licensing, scope of practice and reimbursement. Rapid changes in technology and health care delivery systems will continue to cause health care providers and patients to increase their use of telehealth. While there are many opportunities for health care providers to implement and use telehealth, they must continue to closely monitor the changing regulatory landscape to ensure compliance, receive reimbursement, and avoid potential pitfalls and exposure to liability.