Abstract
BackgroundFederally Qualified Health Centers (FQHCs) deliver care to 26 million Americans living in underserved areas, but few offer telemental health (TMH) services. The social missions of FQHCs and publicly funded state medical schools create a compelling argument for the development of TMH partnerships. In this paper, we share our experience and recommendations from launching TMH partnerships between 12 rural FQHCs and 3 state medical schools.ExperienceThere was consensus that medical school TMH providers should practice as part of the FQHC team to promote integration, enhance quality and safety, and ensure financial sustainability. For TMH providers to practice and bill as FQHC providers, the following issues must be addressed: (1) credentialing and privileging the TMH providers at the FQHC, (2) expanding FQHC Scope of Project to include telepsychiatry, (3) remote access to medical records, (4) insurance credentialing/paneling, billing, and supplemental payments, (5) contracting with the medical school, and (6) indemnity coverage for TMH.RecommendationsWe make recommendations to both state medical schools and FQHCs about how to overcome existing barriers to TMH partnerships. We also make recommendations about changes to policy that would mitigate the impact of these barriers. Specifically, we make recommendations to the Centers for Medicare and Medicaid about insurance credentialing, facility fees, eligibility of TMH encounters for supplemental payments, and Medicare eligibility rules for TMH billing by FQHCs. We also make recommendations to the Health Resources and Services Administration about restrictions on adding telepsychiatry to the FQHCs’ Scope of Project and the eligibility of TMH providers for indemnity coverage under the Federal Tort Claims Act.
Highlights
Federally Qualified Health Centers (FQHCs) deliver care to 26 million Americans living in underserved areas, but few offer telemental health (TMH) services
Based on our experience launching the SPIRIT trial, the remainder of this paper describes the major barriers and solutions to establishing a sustainable Telemental Health (TMH) program between FQHCs and state medical schools that does not involve patients having to navigate to a different health care system
The most common approach to TMH requires the patient to become a patient at the distant-site. This approach is sub-optimal because: 1) the patient is burdened with having to navigate to another health care system, 2) the TMH providers do not document in the FQHC EHR, and 3) the distant-site reimbursement from Medicaid is not eligible for supplemental Prospective Payment System (PPS) payments
Summary
For safety and quality assurance purposes, it is critical that the TMH providers have access to the FQHC’s EHR. Many states[37] and payers[38] have additional billing restrictions including: 1) requiring patients to sign a telemedicine consent form, 2) receipt of a pre-authorization from the insurance company, 3) requiring patients to first have a face-to-face encounter with the TMH provider, 4) limitations on provider type, 5) limitations on the type of clinic setting (for originating and/or distant-sites), and 6) the rurality or shortage area designation of the originating-site’s location These requirements do not necessarily need to be justified at time of billing, but they could be subject to audit and should be documented in the EHR
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