Physical distancing is currently the central weapon in the fight against the COVID-19 pandemic. That’s an important reason to ensure that employees have access to telemedicine and virtual care services. But not all telemedicine is the same, and it’s important to understand the different forms of telemedicine, as well as what it can and can’t do. First off, it’s important to acknowledge that physical testing and providing treatment for COVID-19 is generally out of the scope of traditional telemedicine solutions – although a telemedicine provider may be able to screen for COVID-19 and order testing if necessary. And while we are seeing new and existing telemedicine providers pivot to a “virtual primary care model” that provides more than just consultations on acute conditions, they still aren’t able to match the level of care and follow-up that can be delivered via a traditional office setting. Virtual visits with a patient’s own provider come closer to filling this gap, but many issues are still best treated face-to-face.
That said, all telemedicine services are instrumental in helping manage this pandemic simply by keeping members who do not need to be seen in person out of physician offices, urgent care facilities, and emergency rooms, lessening the potential exposure of individuals who don’t have the virus and allowing the brick and mortar systems to focus on those who do. And while actual testing and confirming infection at the laboratory is not possible virtually, many virtual care and other emerging virtual triage solutions have taken the CDC guidelines and created an AI-driven intake process, which efficiently triages members to an appropriate care setting for testing and treatment if necessary.
Telemedicine, virtual care solutions and virtual provider visits
Traditional telemedicine solution. If you don’t currently offer telemedicine to your employees, we recommend reviewing your existing contracts for potential access to these types of services. All major medical carriers in the US offer some form of telemedicine, and even if you didn’t implement those services in the past, carriers may be flexible in offering short implementation windows.
Clearly, telemedicine has an important role to play in the context of a pandemic. However, it is important to be aware of the limitations and have realistic expectations. As demand for the services increase, the increased call volume results in longer wait times, which can be especially frustrating in stressful situations. In communicating with employees about using telemedicine, you might warn them about longer wait times but also remind them that they will be waiting in the safety of their own home to speak with a physician. At the same time, there are steps vendors can take to better manage the volume, such as scheduled call-backs and chat-based intake services. Many have instituted processes to credential physicians more quickly, which has proven successful. We suggest working closely with your telemedicine vendor to understand potential wait times your employees may experience and what options they may suggest to improve experience with their service.
Virtual care solution. In addition to a variety of newer market entrants, many of the traditional telemedicine vendors are pivoting to a virtual primary care approach. Services are being added to improve intake & triage, provide a broader scope of services and lengthen the continuum of care. It pays to take some time to evaluate the full market and consider innovative solutions along with understanding your current vendor’s roadmap & additional services.
In both cases, several vendors in the US are offering short-term contracts with nimble implementation plans. This gives employers a quick way to roll out virtual care.
Virtual provider visits. Thanks to additional flexibility from regulators, virtual consultations with a patient’s own PCP or other provider are now available. Recent guidance allows covered healthcare providers to use popular applications that enable video chats (FaceTime, Skype etc.) provided in good faith during the public health emergency. When communicating with employees about their virtual options, you may want to suggest that they check with their current provider and ask about options.
Programs (such as EAP) and medical plans typically have systems in place to provide clinically appropriate care through tele-video services. With the onset of COVID-19 risks, some of the carriers have opened up the opportunity for therapists to deliver care to members exclusively through telephone, as an increased measure to accommodate members at high risk of exposure or to support “shelter in place” orders. There are limitations on the nature of need (e.g., complex diagnosis) and level of support (e.g., prescribing of medications) that members may need. In some cases, it may be necessary for the member to attend a video session vs. telephonic. In complex situations, telephone and/or video will not be clinically appropriate. In other cases, the state may have strict rules about the technology that may be used for telemedicine. In general, it is important to be aware that video and/or telephonic delivery of care may not address a member’s needs completely.
Many EAPs and carriers offer self-guided apps using evidence-based practices such as cognitive behavioral treatment (CBT) and positive psychology to assist members in coping with the natural reactions of stress, anxiety, fear and isolation. The CDC and the National Institute of Mental Health (NIMH) recommend that those with mental health conditions should continue with their treatment and develop a plan for tele-health sessions with their providers. In some cases, providers may encourage members to use the self-guided apps between sessions to practice skills and help manage symptoms.
Providing telemedicine to non-enrolled employees: Compliance considerations
Telemedicine and virtual care can also be useful to provide services to employees who are not enrolled in the employer’s medical plan. If you are an employer with a large part-time population, these short-term virtual care offerings may be appealing, but it is important to know the potential regulatory challenges. Specifically, under the definitions provided through the Employee Retirement Income Security Act (ERISA) and the Public Health Services Act (PHSA), common telemedicine services likely fall under the definitions of a “group health plan”. Because telemedicine can be considered a “group health plan”, these programs are subject to the regulations under the Affordable Care Act and other laws. It may be possible, however, to offer telemedicine through an excepted benefit – an employee assistance plan (EAP) or an onsite medical clinic -- and avoid having to comply with some of those requirements. Before making these solutions available to employees not enrolled on your major medical plan, make sure to check with your ERISA counsel for considerations.
Bottom line – if you’re an employer, your members need access to telemedicine and the market is responding. Relaxed regulations and new short-term contracts are making telemedicine more accessible than ever. While it’s important to understand the variety of telemedicine programs available and what each type can and can’t do, the value of telemedicine now – and its potential for the future -- has never been more clear.
Thanks to Frances Andreasen, Kate Brown, Jeff Dobro, Sandra Kuhn, Elissa Rosenbaum, Alisa Trugerman and David Zieg for contributing to this post.