Quality Framework for Telehealth in the SNF Setting |
October 1, 2022 CMS is ending waivers that have allowed unlimited telehealth visits in nursing facilities to be performed by physicians and non-physicians as of May 7, 2022, thereby reinstating the requirement for in-person visits per 42 CFR §483.30. The ending of these waivers does not coincide with an ending of all telehealth waivers in all settings. The reasoning behind this is outlined in QSO 22-15-nh & NTLTC & LSC, out of a concern “about how residents’ health and safety has [sic] been impacted by the regulations that have been waived, and the length of time for which they have been waived.” The California Association of Long Term Care Medicine (CALTCM) is the medical voice of long-term care in California. We advocate for quality patient care and achieve our mission through education and policy. We are in full support of measures to reinforce quality of care, and we believe there is an opportunity to leverage telehealth to do so in both urban and rural settings. Telehealth, is a broad term that refers to providing medical care remotely rather than in-person. In the broadest sense, telehealth includes connecting by phone or video, sending and receiving information, maintaining files electronically, and remote medical monitoring (U.S. Department of Health and Human Services, 2022). It can also include training providers to use telehealth technology, the process of setting up necessary equipment, and other activities involved with delivering telemedicine to patients. The terms telehealth and telemedicine are often used interchangeably, yet, there are differences. Telemedicine is “the practice of medicine using technology to deliver care at a distance” (Mao et al., 2022). Although the focus of this document primarily involves direct patient care, given the inclusion of training as well as the need to discuss the benefits and challenges of using equipment, we use the term “telehealth” throughout this document. While in-person visits may allow a provider increased diagnostic information, and facilitate communication with the patient, family and staff, telehealth visits increase opportunities to observe residents, and interact with staff and families with greater frequency. Telehealth also allows access to specialty visits that are presently not readily available to most nursing home and assisted living residents. Many specialty visits occur in the physicians’ offices and thus require residents to leave the facility usually accompanied by facility staff, thereby adding transportation, coordination and staffing challenges. Leaving the facility may reduce participation in activities and may be disconcerting for cognitively impaired residents. Telehealth facilitates optimal care management and minimizes the potential for cancellation of services to frail older adults in SNF, ALF, and smaller residential care (e.g. board-and-care) settings. Nuanced guidance is needed to ensure that patient care is delivered within the competency range allowed by current telehealth technology. We propose the following guidance:
Medicare facility fees, used appropriately in conjunction with a telehealth visit, should recognize the demands on staff, including technical assistance and clinical input necessary for visit efficiency and value. Download PDF Now |