Internally at RGA, we differentiate between the words ‘Telehealth’ and ‘Telemedicine’. However, outside of RGA the words ‘Telehealth’ and ‘Telemedicine’ are used interchangeably and can encompass a much broader scope of virtual healthcare services than how we define these words at our company.
This is how we define Telehealth and Telemedicine:
Telemedicine (updated definition for 2021 plan year and new amendments this year): covers medically necessary healthcare services between you and your physician to consult, treat, and prescribe for medical conditions. This benefit includes audio and video communication services, such as video conferencing and scheduled telephone visits. Telemedicine visits must be initiated at the request of you or your authorized provider, and replace the need for an in-person office visit. Scheduling and record-keeping standards that apply to in-person visits also apply to telemedicine visits.
Telehealth refers specifically to our buy-up MDLIVE partner product that many of our clients offer as a benefit for their members. Clients that choose MDLIVE as an added benefit decide the types of services (medical only, medical plus behavioral health, medical plus dermatology, or medical plus behavioral health, and dermatology).
What has changed?
COVID-19 is forcing dramatic changes in Telemedicine and Telehealth access and delivery.
Many non-essential medical providers have closed their offices during shelter-in-place orders or cancelled appointments for non-acute services.
People still need access to quality medical care without exposing themselves to extra germs by walking into a doctor’s office. Health officials warn people to stay away from medical facilities unless they need emergency care.
A wave of regulatory changes emerge making way for seismic shifts in telemedicine and telehealth:
- On March 17th the Trump Administration and the Department of Health and Human Services (HHS) announced unprecedented steps to expand Americans' access to telehealth services during the COVID-19 outbreak. The Centers for Medicare & and Medicaid Services (CMS) expanded Medicare coverage for telehealth visits, the HHS Office for Civil Rights (OCR) announced it will waive potential HIPAA penalties for good faith use of telehealth during the emergency, and the HHS Office of Inspector General (OIG) provided flexibility for healthcare providers to reduce or waive beneficiary cost-sharing for telehealth visits paid by federal healthcare programs.
- On March 25th the Oregon Dept of Consumer and Business Services announced telehealth expectations for insurance plans.
- On March 26th Gov. Inslee signed a proclamation on telehealth that provides payment parity between health care services provided in-person and those provided through telemedicine.
- On March 27th the 116th US Congress passed the CARES Act which, among other things, provides safe harbor for waiver of telehealth and telemedicine deductibles for high deductible health plans. The CARES Act is an economic stimulus bill.
- On March 30th the Federal Communications Commission (FCC) announced that it is launching a new telehealth program aimed at using $200M in new federal funding to improve broadband connectivity for connected health services.
- During March 2020, 35 states and the District of Columbia opened their virtual borders by lifting their interstate licensure restrictions to allow doctors in any state to treat patients in their states. Currently, WA has not waived licensure, however, WA is part of the 29 state Interstate Medical Licensure Compact so some out-of-state providers may be eligible to practice in WA if they meet additional requirements.
Thus, providers are quickly digesting these changes and standing up new telemedicine capabilities.
How will my employees know if local community providers have telemedicine capability?
Members will need to call their providers to confirm if the provider has added this capability. Some providers may already serve members via telemedicine. Other providers are contacting their existing patients as telemedicine capabilities become available. Many community providers only offer telemedicine for their existing patients.
How are we accommodating plan changes for Telemedicine and Telehealth?
Some customers have already reached out to us to add telemedicine to their benefits so that members can access healthcare services without visiting a brick and mortar location. If you would like to add an option for telemedicine via community providers, we can make that change to your plan design immediately. This change option is available in the COVID-19 Benefit Change Request Form.
Add Telehealth through MDLIVE
If you would like to add telehealth service via our MDLIVE telehealth product, we can also make that change. Please reach out to your Account Manager and we will send you a separate form to confirm your MDLIVE coverage preferences.
How long will it take to add MDLIVE
Adding MDLIVE services will likely take 10-15 days for MDLIVE to be set up for the first time. If you are simply making a change to your existing MDLIVE benefits, then the changes will only take a few days.
MDLIVE typically has a 60-day lead time for adding a new client. MDLIVE is working closely with us to add new clients on a much shorter lead time of approximately 10-15 days during this pandemic. During these rush additions we will need to receive information from you on a short turnaround time. We will provide you email templates that you can share with your members to invite them to register for MDLIVE or to inform them of upgrades to their MDLIVE coverage.
Can MDLIVE help members with COVID-19
MDLIVE providers can screen members for COVID-19. They cannot order COVID-19 lab tests. If you have a copay or deductible set up for non-COVID-19 related services with MDLIVE they cannot waive the copay or deductible upfront for COVID-19 related services. Members will have to pay their co-pay upfront and then we will mail them a reimbursement check after the claim is processed.
Can I add MDLIVE month-to-month?
Adding MDLIVE requires a minimum 90-day commitment post-implementation and at least a 30-day termination notice. MDLIVE services are available 24 hours per day and 365 days per year via phone, online via the myHMA portal or MDLIVE.com, or through the MDLIVE mobile app.
Each virtual consultation (visit) has a fee in addition to the PEPM. The fee schedule is based on the service provided. Current MDLIVE fee rates:
Medical: $38; Behavioral Health and Psychiatric Services: $85-$260; Dermatology: $60
MDLIVE wait times
Please be aware that wait times are longer than usual due to the high volume of calls MDLIVE & all telehealth vendors in the market are currently receiving. Members can choose to schedule an appointment at a later time or may need to wait 2-4 hours for an appointment. MDLIVE is actively working to increase capacity to support the surge in volumes. Please note, at this time, MDLIVE cannot order a COVID-19 diagnostic test.