Treatment In Place Bill Introduced in House
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Tag: Community Paramedicine / Mobile Integrated Health (MIH)
HHS OIG Report on Telehealth for Medicare Beneficiaries in COVID-19
From HHS Office of Inspector General on March 15, 2022
Telehealth Was Critical for Providing Services to Medicare Beneficiaries During the First Year of the COVID-19 Pandemic
WHY WE DID THIS STUDY
The COVID-19 pandemic created unprecedented challenges for how Medicare beneficiaries accessed health care. In response, the Department of Health and Human Services (HHS) and the Centers for Medicare & Medicaid Services (CMS) took a number of actions to temporarily expand access to telehealth for Medicare beneficiaries. CMS allowed beneficiaries to use telehealth for a wide range of services; it also allowed beneficiaries to use telehealth in different locations, including in urban areas and from the beneficiary’s home.
This data brief provides insight into the use of telehealth in both Medicare fee-for-service and Medicare Advantage during the first year of the COVID-19 pandemic, from March 2020 through February 2021. It is a companion to a report that examines the characteristics of beneficiaries who used telehealth during the pandemic. Another report in this series identifies program integrity concerns related to telehealth during the pandemic. Understanding the use of telehealth during the first year of the pandemic can shed light on how the temporary expansion of telehealth affected where and how beneficiaries accessed their health care. This information can help CMS, Congress, and other stakeholders make decisions about how telehealth can be best used to meet the needs of beneficiaries in the future.
HOW WE DID THIS STUDY
We based this analysis on Medicare fee-for-service claims data and Medicare Advantage encounter data from March 1, 2020, to February 28, 2021, and from the prior year, March 1, 2019, to February 29, 2020. We used these data to determine the total number of services used via telehealth and in-person, as well as the types of services used. We also compared the number of services used via telehealth and in-person during the first year of the pandemic to those used in the prior year.
WHAT WE FOUND
Over 28 million Medicare beneficiaries used telehealth during the first year of the pandemic. This was more than 2 in 5 Medicare beneficiaries. In total, beneficiaries used 88 times more telehealth services during the first year of the pandemic than they used in the prior year. Beneficiaries’ use of telehealth peaked in April 2020 and remained high through early 2021. Overall, beneficiaries used telehealth to receive 12 percent of their services during the first year of the pandemic. Beneficiaries most commonly used telehealth for office visits, which accounted for just under half of all telehealth services used during the first year of the pandemic. However, beneficiaries’ use of telehealth for behavioral health services stands out. Beneficiaries used telehealth for a larger share of their behavioral health services compared to their use of telehealth for other services. Specifically, beneficiaries used telehealth for 43 percent of behavioral health services, whereas they used telehealth for 13 percent of office visits.
WHAT WE CONCLUDE
Telehealth was critical for providing services to Medicare beneficiaries during the first year of the pandemic. Beneficiaries’ use of telehealth during the pandemic also demonstrates the long-term potential of telehealth to increase access to health care for beneficiaries. Further, it shows that beneficiaries particularly benefited from the ability to use telehealth for certain services, such as behavioral health services. These findings are important for CMS, Congress, and other stakeholders to take into account as they consider making changes to telehealth in Medicare. For example, CMS could use these findings to inform changes to the services that are allowed via telehealth on a permanent basis.
2021 Legislative Priorities Highlights & Wrap Up
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EMS.gov | Telemedicine Framework for EMS and 911
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Senate Passes Ambulance Treatment in Place Language
On Saturday, the U.S. Senate passed language for Medicare coverage of emergency treatment in place of lower acuity patients by ground ambulance services providers and suppliers during the COVID-19 public health emergency (PHE). The language is from S. 149 by Senators Cortez Masto (D-NV) and Cassidy (R-LA) and passed as part of the $1.9 Trillion American Rescue Plan (H.R. 1319). The House is scheduled to vote and expected to pass the package tomorrow.
The American Ambulance Association along with the International Association of Fire Chiefs, International Association of Firefighters, National Association of EMTs and National Volunteer Fire Council pushed for passage of the bill language.
S. 149 would authorize the Centers for Medicare and Medicaid Services (CMS) to waive the transport requirement under Medicare for treatment in place for 9-1-1 or equivalent ambulance responses in which community EMS protocols dictate that the patient not be transported to a facility. The waiver would apply during the public health emergency.
Similar to other waivers provided by Congress for Medicare coverage during the pandemic, CMS would not be required to implement the policy. However, CMS has done so in all other situations and has also made the coverage retroactive to the beginning of the PHE. Upon passage of the language, the AAA will strongly advocate for CMS to implement the waiver and make it retroactive.
The AAA will be offering educational services to our members on the requirements of the proposed new policy and how to bill for covered services.
HHS OIG Issues Advisory Opinion on Community Paramedicine
HHS OIG Issues Advisory Opinion Permitting Community Paramedicine Program Designed to Limit Hospital Readmissions
On March 6, 2019, the HHS Office of the Inspector General (OIG) posted OIG Advisory Opinion 19-03. The opinion related to free, in-home follow-up care offered by a hospital to eligible patients for the purpose of reducing hospital admissions or readmissions.
The Requestor was a nonprofit medical center that provides a range of inpatient and outpatient hospital services. The Requestor and an affiliated health care clinic are both part of an integrated health system that operates in three states. The Requestor had previously developed a program to provide free, in-home follow-up care to certain patients with congestive heart failure (CHF) that it has certified to be at higher risk of admission or readmission to a hospital. The Requestor was proposing to expand the program to also include certain patients with chronic obstructive pulmonary disease (COPD). According to the Requestor, the purpose of both its existing program and its proposed expansion was to increase patient compliance with discharge plans, improve patient health, and reduce hospital inpatient admissions and readmissions.
Under the existing program, clinical nurses screen patients to determine if they meet certain eligibility criteria. These include the requirement that the patient have CHF and either: (1) be currently admitted as an inpatient at Requestor’s hospital or (2) be a patient of Requestor’s outpatient cardiology department, and who had been admitted as an inpatient at Requestor’s hospital within the previously 30 days. The clinical nurses would identify those patients at higher risk of hospital admission based on a widely used risk assessment tool. The clinical nurses would also determine whether the patient had arranged to receive follow-up care with Requestor’s outpatient CHF center. Patients that do not intend to seek follow-up care with the CHF center, or who have indicated that they intend to seek follow-up care with another health care provider, would not be informed of the current program. Eligible patients would be informed of the current program, and offered the opportunity to participate. The eligibility criteria for the expanded program for COPD patients would operate in a similar manner.
Eligible patients that elect to participate in the current program or the expanded program would receive in-home follow up care for a thirty (30) day period following enrollment. This follow up care would consist of two visits every week from a community paramedic employed by the Requestor. As part of this in-home care, the community paramedic would provide some or all of the following services:
- A review of the patient’s medications;
- An assessment of the patient’s need for follow-up appointments;
- The monitoring of the patient’s compliance with their discharge plan of care and/or disease management;
- A home safety inspection; and/or
- A physical assessment, which could include checking the patient’s pulse and blood pressure, listening to the patient’s lungs and heart, checking the patient’s cardiac function using an electrocardiogram, checking wounds, drawing blood and running blood tests, and/or administering medications.
The community paramedic would use a clinical protocol to deliver interventions and to assess whether a referral for follow-up care is necessary. To the extent the patient requires care that falls outside the community paramedic’s scope of practice, the community paramedic would direct the patient to follow up with his or her physician. For urgent, but non-life threatening conditions, the community paramedic would initiate contact with the patient’s physician.
The Requestor certified that the community paramedics would be employed by the Requestor on either full-time or part-time basis, and that all costs associated with the community paramedic would be borne by the Requestor or its affiliates. The Requestor further certified that no one involved in the operation of the program would be compensated based on the number of patient’s that enroll in the programs. While one of the states in which the Requestor operates does reimburse for community paramedicine services, Requestor certified that it does not bill Medicaid for services provided under the program.
The question posed to the OIG was whether any aspect of the program violated either the federal anti-kickback statute or the prohibition against the offering of unlawful inducements to beneficiaries.
In analyzing the program, the OIG first determined that the services being offered under the program offer significant benefit to enrolled patients. The OIG specifically cited the fact that one state’s Medicaid program reimbursed for similar services as evidence of this value proposition. For this reason, the OIG concluded that the services constitute “remuneration” to patients. The OIG further concluded that this remuneration could potentially influence a patient’s decision on whether to select Requestor or its affiliates for the provision of federally reimbursable items and services. Therefore, the OIG concluded that the program implicated both the anti-kickback statute and the beneficiary inducement prohibition.
The OIG then analyzed whether the program would qualify for an exception under the so-called “Promoting Access to Care Exception.” This exception applies to remuneration that improves a beneficiary’s ability to access items and services covered by federal health care programs and which otherwise pose a low risk of harm. The OIG determined that while some aspects of the program would likely fall within this exception, other aspects would not. Specifically, the OIG cited the home safety assessment as not materially improving a beneficiary’s access to care.
Having concluded that there was no specific exception that would permit the arrangement, the OIG then analyzed the arrangement under its discretionary authority, ultimately concluding that the program posed little risk of fraud or abuse. In reaching this conclusion, the OIG cited several factors:
- The OIG felt that the potential benefits of the program outweighed the potential risks of an improper inducement to beneficiaries. The OIG cited the fact that beneficiaries must have already selected Requestor or its associated clinic as their provider of services before learning about the program. As the OIG indicated “the risk that the remuneration will induce patients to choose Requestor or the Clinic for CHF- or COPD-related services is negligible because patients already have made this selection.” The OIG also noted that the community paramedic will inform beneficiaries of their right to choose a different provider prior to referring the beneficiary to the Requestor or its clinic for services outside the scope of the program.
- The OIG noted that, to the extent the program works as intended, it would be unlikely to lead to increased costs to federal health care programs. As noted above, Requestor had certified that it would not bill federal health care programs for the services of the community paramedic.
- The program was designed in a way as to minimize the potential for interference with clinical decision-making.
- The Requestor certified that it would not advertise or market the program to the public, thereby minimizing the chances of beneficiaries learning about the program prior to selecting Requestor for their CHF- or COPD-related care.
- The OIG noted that the program appeared to be reasonably tailored to accomplish the goal of reducing future hospital admissions. For example, the OIG cited the fact that the Requestor limited inclusion in the program to patients deemed to be at a higher-than-normal risk of hospital admission or readmission, and that it made these determinations using a widely used risk assessment tool. The OIG noted that these patients would likely benefit from the continuity of care offered under the program. In addition, the OIG noted that the community paramedics would be in a position to keep the patients’ physicians appraised of their health by documenting all of their activities.
Potential Impact on Mobile Integrated Health and/or Community Paramedicine Programs
OIG advisory opinions are issued directly to the requestor of the opinion. The OIG makes a point of noting that these opinions cannot be relied upon by any other entity or individual. Legal technicalities aside, the OIG’s opinion is extremely helpful to the industry, as it lays out the factors the OIG would consider in analyzing similar arrangements. Thus, the opinion is extremely valuable to ambulance providers and suppliers that current operate, or are considering the operation of, similar mobile integrated health and/or community paramedicine programs.
MedPAC Examines Beneficiary Use of Emergency Departments
During its October meeting, the Medicare Payment Advisory Commission (MedPAC), reviewed Medicare’s current policies related to non-urgent and emergency care, as these topics relate to the use of hospital emergency departments (EDs) and urgent care centers (UCCs). The Commission is examining this topic because the use of ED services in recent years has grown faster than that of physician offices. At the same time, the share of ED visits that are coded as high acuity has increased.
The Commission is exploring Medicare beneficiaries’ use of EDs and UCCs for non-urgent services. In addition, the Commission is analyzing ED coding to determine if the increase in coding high-acuity visits reflects real change in the patients treated in EDs. This slide deck shows the potential savings Medicare could realize if beneficiaries shift certain care to the UCC setting.
During the meeting, the staff sought feedback from Commissioners for developing next steps. This topic will likely continue to be addressed in future meetings.
From the perspective of ambulance payment reform, the observations made by the Commissioners and staff would also seem to support incorporating scope-appropriate ambulance services in the context of community paramedicine or treatment at the scene with referral. While additional work needs to be done by the ambulance community before these services can be incorporated into the Medicare reimbursement program, discussions like the one at MedPAC last week, show the importance of getting the details right so that ambulance services can be part of new payment models likely to be considered.
The American Ambulance Association is leading the effort with the Medicare program to develop appropriate models that account for the cost of providing services through sustainable reimbursement rates, rather than the use of temporary grants. We are also focused on ensuring services align with the scope of practice laws. Led by the Payment Reform and the Medicare Regulatory Committees, our efforts include regular meetings and discussions with leaders at the Centers for Medicare & Medicaid Services, as well as key Members of Congress. Follow us on Facebook and Twitter to learn more about our ongoing efforts.
Ambulance Cost Data Collection is Coming
Although the most prominent ambulance provision passed in the Bipartisan Budget Act of 2018 (H.R. 1892) was the five-year extension of the Medicare add-ons, the Act also included important language directing the Centers for Medicare and Medicaid Services (CMS) to collect cost and other financial data from ambulance service suppliers and providers.
This week, an editorial from AAA Senior Vice President of Government Affairs Tristan North was featured in the June issue of JEMS‘s “EMS Insider”. Read the full article►
Changing the Face of EMS for the New Century
EMS has always been the forefront of medicine, delivering care to the sick and injured in various roles dating as far back as the Civil War. It has come a long way from the days of horse and buggy. Yet, where are we going now?
One look at the trajectory of Nursing indicates where we are headed. When Nursing first started, the profession was comprised of caring women who were viewed and treated as indentured servants, subservient to the male dominated physicians. Nursing evolved when the “servant” became educated. What followed were thousands of women beginning to diagnose, conduct research and improve outcomes in the healthcare field. Soon thereafter, they broke free of the care assistant model they were in. I see EMS following the same path.
The ambulance industry started out as transporters, with a curriculum that was adopted and funded by the Department of Transportation (DOT). The industry has roots in DOT, Police Departments, Fire Departments and the military, but are truly physician extenders that should be firmly rooted in Health Departments. EMS is now developing a language, doing research, obtaining national accreditation for our schools, even supporting continuing education with CAPCE. But we need to do more.
Outreach will help accomplish what many have started. We need to consider the picture the public has of EMS, especially when we have overlooked self-promotion for decades.
Let’s be the ones who show the public what EMS is and is capable of. I look forward to EMS education mirroring, “The Georgia Trauma Commission,” which collaborated with the Georgia Society of the American College of Surgeons and the Georgia Committee on Trauma to create the “Stop the Bleed” campaign. This inspiring crusade is designed to train school teachers, nurses and staff across the state on how to render immediate and potentially life-saving medical aid to injured students and co-workers while waiting for professional responders to arrive.” (2018, para. 4) This type of training gives us face time with the public so they can learn what we do and what we do not.
One of the other important outreach programs to help us in this endeavor is the Community Paramedic Program. We are seeing this education transform EMS into new and exciting roles in the community. “First responders frequently respond to calls for social services. So, the emergency responders may know of people who need some sort of services or resources,” (Todd) Babbitt, a former fire chief, said. “This team could help connect those people with the services they need. It’s about getting everybody to work together and communicate.” (2018, para. 4)
What we can do is start to get EMS in front of the public. Teach. And open our historically closed doors to the folks that make it easier to do our jobs. Educate others and learn together how our roles are changing modern day healthcare while embracing the change. Otherwise we risk being left in the dust by our progressive healthcare brethren.
References
(2018, Feb 1st, 2018). Ga. School Nurses Train to Stop the Bleed. The Brunswick News. Retrieved from https://www.emsworld.com/news/219782/ga-school-nurses-train-stop-bleed
(Ed.). (2018, January 30th, 2018). Conn. Fire Chiefs to Form Community Action Team. Norwich Bulletin. Retrieved from https://www.emsworld.com/news/219757/conn-fire-chiefs-form-community-action-team
Cataldo Ambulance’s Ron Quaranto on Mobile Integrated Health
As a current mobile integrated health provider, we recognize the values of an MIH program which most importantly provides quality patient care to those in need, often in the comfort of their own homes. This is often done under the direction of the patient’s primary care physician in conjunction with the patient’s healthcare team. This allows for the patient to maintain their quality of life while receiving the medical attention they need—and ultimately reducing the healthcare expenses of hospitalization.
Ron Quaranto
COO, Cataldo Ambulance Service
Cross-Cultural Communication for EMS
Ambulance services interact with people from all walks of life, and from all parts of the world. AAA checked in with expert Marcia Carteret, M.Ed., for some tips for communicating more effectively with people from other cultures. Marcia is an instructor of intercultural communications at University of Colorado School of Medicine in the Department of Pediatrics. She trains residents, faculty, and staff in healthcare communication with a focus on cross-cultural patient care and low health literacy. She has also trained in over 120 private pediatric and family practices across Colorado.
Marcia also developed a robust cross-cultural toolkit for AAA members. [Learn more about AAA membership]
Barriers to Understanding
In all healthcare settings, successful communication with patients and families depends on awareness of three key barriers to their understanding and compliance:
- Cultural Barriers: Understanding western medicine and the U.S. healthcare system is a challenge for many of us, but it is especially problematic for recent immigrants and refugees. 72% of U. S. population growth in the next 20 years will come from immigrants, or the children of immigrants.
- Limited English Proficiency: The number of people who spoke a language other than English at home grew by 38 percent in the 1980s and by 47 percent in the 1990s. While the population aged 5 and over grew by one-fourth from 1980 to 2000, the number who spoke a language other than English at home more than doubled.
- Low Health Literacy: While poor understanding of the health care system and difficulty understanding health care instructions may be associated with language and cultural barriers, low health literacy is also found in patients who are proficient in English and who share the common U.S. culture. This latter group may be especially at risk of having their low health literacy go unrecognized. 90 million “mainstream” Americans cannot understand basic health information.
Addressing These Barriers
How do people understand one another when they do not share a common cultural experience? Nowhere is this a more pressing question than in healthcare settings, especially in emergencies. There is no easy list of things “to do” or “not to do” that can be applied to each culture. What can be useful are communication guidelines that work for people from all cultures. These guidelines are also important for people with low health literacy.
[quote_left]“The essence of cross-cultural communication has more to do with releasing responses than sending messages. And it is most important to release the right responses.” — Edward T. Hall[/quote_left]
Perhaps the most important is framing questions to elicit appropriate answers. As Edward T. Hall, anthropologist and cross-cultural researcher wrote,“The essence of cross-cultural communication has more to do with releasing responses than sending messages. And it is most important to release the right responses.” What could be more crucial when, for example, an EMT or paramedic is attempting to establish level of consciousness by directly eliciting information from a patient? Being able to get quality responses from patients from any culture is a communication skill that comes with experience. Learning and practicing a set of strategically designed questions is key to building confidence in this important skill.
Key Communication Tips
- Explain your professional role
911 is the number to dial in an emergency, but some people may not understand the roles of different emergency responders. You can’t expect people who are still learning to function in the U.S. mainstream society – recent immigrants or refugees especially – to understand the role of the EMT or paramedic.
Suggested explanation: “I am not a doctor. I am an emergency medical professional. I have come to help because someone called 911. I will take this person who is hurt/sick to the hospital safely.”
- Use simple familiar words and short sentences
“Stabilize” is a complex word, even though it might be the best word to describe what you do for a patient in an emergency. Help is a better word. With Limited English Proficiency (LEP) patients and families, the 5¢ word is always better than the 75¢ word. Basics such as give, take, more, less will be better choices than administer, increase, decrease.
- Be clear when you are asking a question versus giving an instruction.
Running questions and statements together is confusing for second language learners. Avoid sentences like this: “It looks like you are having a reaction (a statement of observation) so I need to know if you have taken any medication that made you feel sick.”Examples of concise phrasing:- “What medicine have you taken?
- “Show me this medicine.”
- “Show me where it hurts.”
- Avoid close-ended questions
These usually begin with do, did, does, is, are, will, or can. These can be answered with a simple yes or no – or a head nod. Avoid the use of close-ended questions with Limited English Proficiency (LEP) patients because in many cultures people will frequently simply say yes even if they don’t understand you. - Use open-ended questions
These usually begin with the 5 Ws – who, what, when, where, why (and how or how many). It is awkward to answer these questions with a nod, shrug, or simple yes/no. For example, you might ask: “When did you take these pills?” instead of “Did you take these pills?” - Avoid starting sentences with negations such as isn’t and didn’t.
Though this is a common speech pattern in English, it may be confusing for people who speak a different native tongue. For example: Didn’t you call 911? (Read more about this speech pattern.) - Clarify understanding – yours and theirs
Even if you are using simpler words and shorter sentences, you can’t be certain there has been communication until the receiver acknowledges it with feedback. Remember, head nodding does not count as feedback with people from many different cultures. Even with Americans, and definitely with children, head nodding is often a sign of partial comprehension. So you must ask clarifying questions. - Repeat back what you have understood.
- Examples: “Yes? – you took the medicine?”
- “Yes? – you are his/her grandmother?”
- Not understanding vs. misunderstanding
When people do not understand what you say, there is more likely to be an indication of confusion than when they MISunderstand you. A person struggling with English, for example, may ask you to repeat what you have said. Their face may show confusion. But when people MISunderstand, it can be far less obvious. For example, the English words want and won’t sound very much alike to a non-native speaker. You may say to a person, “I want to help you,” but she may hear “I won’t help you.” She may be perplexed that this is your response, but she may be very inclined to accept the word of a healthcare professional. She may perceive you as being uncaring, but certainly won’t say so. Many MISunderstandings go unnoticed by both parties. Asking clarifying questions is crucial. - Speak slowly and clearly—NOT loudly
Often when people don’t understand our language, we treat them as if they are hearing impaired or “slow” without realizing we are doing so. Articulate your words in shorter phrases rather than just speaking more loudly.
Cultural Norms
Cultural norms vary around the world. Here are some key norms to keep in mind when assisting patients and their families.
- Eye Contact
An EMT or Paramedic will often be perceived as an authority figure by the people from more traditional cultures. If a person is avoiding eye contact while listening to you or while answering questions, be aware that in some cultures direct eye contact with an authority figure is very rude. In trying to be respectful, people may appear to be avoiding looking you in the eye. This is not to be taken immediately as any indication of disrespect, dishonesty, or evasiveness - Silence
Silence may be the only response a person can muster if he or she is frightened. Silence might also be a way of showing respect, similar to avoiding eye contact. Being thoughtful about answering a question shows humility and real effort in giving the best answer. Unfortunately, silence on the part of the non-English patient or family member is often interpreted as open hostility by Americans. It can be helpful to say: “I need your help. Please try to answer my questions. Your answers help me help you.” Also, try not to rush answers. Americans allow very little time between questions and responses. Impatient and in a hurry we tend to start talking before the other person is able to answer the question asked. - Reverting to Native Language
Bilingual patients may revert to their language of origin in times of stress, and while this hinders communication with an EMT, it should not be seen as manipulative or uncooperative. Calmly ask the person, “Can you speak in English? Please try English.” If the person does not speak any English, this will at least help them realize you can’t understand.
Summary
As first-responders, EMS is often working in high stakes situations where communication is a challenge even without the added barriers associated with the “triple threat” to healthcare communication—language barriers, cultural understanding, and low health literacy. No matter which culture an EMT or Paramedic is interacting with, the key to good communication is asking good questions and phrasing all dialogue in simple short sentences. It should be clear that a question is being asked or a statement of information is being made by the EMS professional. Asking for clarification is essential. Head nods and affirmative answers should not be accepted immediately as evidence of sufficient understanding or agreement. EMTs will find that enhanced communication skills will not only improve cross-cultural interactions, these skills improve outcomes with all people – even “mainstream” Americans. Also, be aware that low health literacy is a problem for 90 million Americans. Never assume that same-culture communication in English requires less intentional speech on your part.