Before a pandemic forced the rapid adoption of telehealth in the U.S., the Trump administration had already implemented or was taking steps to support the use of telehealth in the Medicare Advantage program. But one remaining barrier for plan adoption of telehealth was the inability to collect diagnosis codes for risk adjustment purposes. CMS temporarily addressed this issue during the pandemic, but as providers anticipate telehealth to play a more permanent role in health care delivery, they are joining with plans to advocate for a permanent shift in MA telehealth policy.
CMS in an April 10 memo to plans stated that MA “organizations and other organizations that submit diagnoses for risk adjusted payment are able to submit diagnoses for risk adjustment that are from telehealth visits when those visits meet all criteria for risk adjustment eligibility, which include being from an allowable inpatient, outpatient, or professional service, and from a face-to-face encounter” (RMA 4/16/20, p. 3). The document said little else, other than specifying that such diagnoses would count only when the services are provided using an interactive audio and video telecommunications system that allows for “real-time interactive communication.”