![]() The email may contain multiple addresses or may be in the form of a spreadsheet, but hospitals are reminded that the information must be encrypted and should not include unnecessary protected health information (PHI), such as patient names. 1 Additionally, CMS reiterated during the CMS Office Hours call on May 7, 2020, that addresses must be provided for each of the locations to which the hospital outpatient department is temporarily relocating. All hospitals that are applying for an extraordinary circumstance relocation exception in response to the COVID-19 public health emergency should notify their CMS Regional Office by email within 120 days of beginning to provide services in the new off-campus location(s) and include the following information: 1) The hospital’s CMS Certification Number (CCN) 2) the address of the current provider-based department (PBD) 3) the address(es) of the relocated PBD(s) 4) the date which they began furnishing services at the new PBD(s) 5) a brief justification for the relocation and the role of the relocation in the hospital’s response to COVID-19 and 6) an attestation that the relocation is not inconsistent with their state’s emergency preparedness or pandemic plan. COVID-19 (Coronavirus) Coding & Billing Resource Center.Continuity of care must be maintained by requiring that medical records from telehealth visits are shared with the patient's medical home and warm handoffs are made whena patient has medical needs that cannot be addressed via telehealth. However, we should be wary of national telehealth platforms that draw patients away from their primary care physician. ![]() The interstate licensing compact is a step in the right direction, but more should be done to permanently remove the barriers for treating across state lines now that telehealth has made it more feasible and common. Physicians should be able to continue to prescribe attention deficit hyperactivity disorder medications to patients they have known since birth after those patients go off to college in another state, for example, or adjust the blood pressure medications of a long-time patient who is visiting family in another state. 4 Moving forward, family physicians must advocate for the continued growth of the compact and decreased barriers to care. The growth of the Interstate Medical Licensure Compact highlights the need to reconsider state-based licensure in the context of telehealth. Originating site requirements for Medicare, Medicaid, and commercial insurance reimbursement should be eliminated entirely. But the pandemic has proven that telehealth has the potential to benefit all patients, regardless of their home address. Prior to the pandemic, many state and federal policies restricted the use of telehealth to patients in rural areas. This has improved health care access for historically marginalized populations and will be beneficial as we continue to strive for health equity. Also, FQHCs and RHCs must continue to be allowed to be the distant site in telehealth encounters. Federal and state policy changes in response to the pandemic have helped regulations catch up to the evolution of telehealth technology by allowing primary care physicians to be compensated for the telehealth services they provide. ![]() Historically, Medicare telehealth policies were highly restrictive, focusing on telehealth mainly as a tool to increase access to sub-specialty care. ![]()
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