Important Changes that May Affect Telehealth Policy During the COVID-19 Pandemic

Dear Editor,

A recent publication in Diabetes Technology & Therapeutics by Crossen et al. ¹ described best practices in setting up telehealth programs for diabetes care. Since their article was written before the current COVID-19 pandemic, my letter highlights important changes in telehealth policy that have occurred during the COVID-19 pandemic and outlines how these changes may affect the successful implementation of a diabetes telehealth program at the current time. Another more comprehensive review on this topic was recently published in JAMA. ² However, this comment specifically addresses policy updates from Centers for Medicare & Medicaid Services (CMS), which were communicated on March 30 and April 30, 2020. These updates will remain in effect during the declared COVID-19 public health emergency (PHE), which was renewed by Department of Health and Human Services Secretary Azar on July 23 and will remain in effect through October 23, 2020. Although the references are CMS-specific, the changes may be generally applied to Medicaid and commercial plans, although providers and beneficiaries alike must check their insurance plans to determine applicability.

In March, the CMS and the office of inspector general notified beneficiaries that nonpublic facing video applications such as FaceTime or Skype could be used for an audio-visual telemedicine visit. Because in-person care could increase the risk of COVID-19 transmission, this was essential and released providers of the need to negotiate contracts with video platform vendors, often a lengthy process that would be a deterrent to immediate medical care. ³

Other and more significant allowances are that CMS is allowing the performance of a telehealth visit in patients' homes and reimbursing for these services regardless of geographic locale (e.g., urban or rural). Furthermore, in CMS' List of Telehealth Services, ⁴ additional common procedural terminology codes were added to the approved list for use during the pandemic, as well as indicating other services requiring a face-to-face encounter (synchronous video or in-person) could be done through audio. This addition supported an effort by CMS to maintain as much health services equity as could be provided in a remote manner during the PHE.

The three changes mentioned use of familiar and common audio–video applications, CMS' recognition of patients' homes as an originating site, and the payment for that service, while also recognizing the telephone as a tool for conducting patient care, have allowed for the expansion and acceptance of telehealth as another mode of care delivery. Any care that can be done outside of a clinic and in your patients' homes is beneficial whether or not there is a PHE, and continuous glucose monitoring (CGM) interpretation is a great addition to the diabetes physician's virtual “bag.”