With staffing shortages around the country, many healthcare facilities are calling on retired physicians and mid-levels to take telehealth shifts. In addition, many ER physicians and other specialists are being asked to work additional hours and take telehealth call. Needless to say, the demands of healthcare workers are increasing and the correct fair market value of their time and services is being called into question.
The most common telemedicine arrangement is referred to as a “hub-and-spoke” arrangement. This involves an originating site (usually a rural hospital) with patients in need of care and a distant site (usually a larger health system) employing or contracting with specialists who deliver care. However, the new Coronavirus Preparedness and Response Supplemental Appropriations Act of 2020 has changed some of these requirements. In addition, many state Medicaid programs are announcing new coverage policies to make it easier to provide telemedicine services.
This new law relaxes many of the current Medicare criteria in order to rapidly expand the use of telehealth as a resource against COVID-19. Pursuant to this law, the Secretary of HHS has the authority to waive the “site” requirements for telehealth services provided to Medicare beneficiaries who are located in an identified “Emergency Area” during an “Emergency Period.” Since the whole country is currently experiencing a public health emergency, the Emergency Period and Emergency Area requirements are met on a nation-wide basis. Prior to this waiver, Medicare/Medicaid could only pay for telehealth on a limited basis which is when the person receiving the service is in a designated rural area and when they leave their home and go to a clinic, hospital, or certain other types of medical facilities for the service.
Telehealth On-Call Fair Market Value
In some cases, a health system will have physicians on-call to respond to a telemedicine encounter. At first, this telemedicine on-call arrangement appears to be very similar to a typical call arrangement for an emergency department. However, utilizing per diems reported in benchmark surveys to determine a telemedicine FMV on-call rate is not exactly appropriate. It is important to remember that call coverage rates published in surveys like MGMA or Sullivan Cotter mostly represents emergency department call coverage. If you are using these survey on-call rates for telemedicine on-call arrangements, the data will likely need to be adjusted. Emergency department call coverage benchmarks are commensurate with the burden of responding in person to the emergency department to perform a consultation, surgery, or other procedure. In a telemedicine arrangement, the on-call physician can likely deliver the consult or examination at his home, office or over the telephone, which is much less burdensome than having to come into the emergency department. In this case, the per diem on-call rates published in the compensation surveys should be discounted to account for the diminished burden.
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The information provided herein is of a general nature and cannot be substituted for an actual fair market valuation opinion in which specialized knowledge is applied to a particular circumstance and specific facts. Therefore, nothing in this article should be construed to offer or render a valuation or legal opinion, and neither Chris David or HealthValue Group cannot take any responsibility for an attempt to use or adopt the information or disinformation presented herein.