A new trajectory 
for telehealth.

There are plenty of competing interests at the table. Healthcare delivery has historically operated on the premise of physician-centric care and the assumption that quality care services could only be delivered in a face-to-face setting—the supposition that physician evaluation should always be hands-on. But sensor-driven and artificial intelligence (AI)-enabled remote patient monitoring devices have challenged that assumption. Interpretation of findings is still the domain of the physician, but telehealth solutions are helping redefine the scope of clinical practice, and helping untether patients and care teams from facility-dependent evaluation and care. 

Beyond the impact on traditional clinical practice, telehealth has been a complicated proposition. State licensure laws have limited the geographical reach of the clinician. The Center for Medicare/Medicaid Services (CMS) has restricted reimbursement for telehealth visits to a small set of extenuating circumstances and brief physician check-ins. Other payers have incentivized telehealth utilization, but limited reimbursement for Medicare visits has stymied more widespread adoption. And the greatest barrier has been a lack of interoperability standards necessary for integrating telehealth solutions into existing information systems and clinical workflows.

Telehealth will need these critical accelerators:

1. Expanded reimbursement 
It remains to be seen what CMS will do to support telehealth reimbursement after the pandemic, but returning to a limited set of use cases is unlikely. A comprehensive look at utilization, an updated coding set to support current and new use cases, and a forward-leaning commitment to telehealth as a care model will be critical. If Medicare will not reimburse, providers will be slow to adopt and future utilization will be limited. And where CMS leads, the payer space will follow.

2. Evolution of data security 

OCR has lifted restrictions on telehealth conferencing tools for six months, but it remains to be seen whether there will be an extension beyond that point. Either way, a closer look at current definitions may be warranted to support expanded adoption of telehealth capabilities. Iterative standards are needed to address data security for these simple and cost-effective applications. Given the simplicity of recording video conversations within these platforms, it will be difficult for providers to store recordings for the requisite six years. As usage of these platforms expands for virtual care, a waiver of the retention requirements under the rule may be needed. Compliance controls around levels and types of encryption—including ownership of keys—and restrictions around data recording will be critical. The option for encryption levels should be disabled, for example, in any “healthcare” version of these platforms. Encryption should be hard set, and consumer tools should use end-to-end encryption without technology provider keys. Beyond that, there will be a need for better standards around integrated IoT devices and protocols for secure data exchange between all telehealth stakeholders—i.e., EHR systems, data warehouses, picture archiving and communication (PAC) systems, telehealth platforms, quality measures and performance reporting, billing and reimbursement, etc.