Active Guidance
3/13/24 - EVC Update
A recent update to Chromium browsers has fixed the root cause of the background effect crashes. The Epic Video Client team anticipates enabling virtual backgrounds for users on up-to-date versions of Google Chrome and Microsoft Edge with next week's Epic Video Client release. We are exercising caution with our testing pass to ensure video visits remain fully functional before restoring this functionality.
We expect this release to be available on 03/21 and will update if that timeline changes in any way.
12/18/23 - EVC Project Update: Specialty Care
In our previous memo, we announced Penn Medicine’s telemedicine transition from BlueJeans to Epic Video Client (EVC). The transition will be finalized by March 31, 2024, and has been occurring by department. As of December 18th, 2023, we have transitioned both Primary Care and Behavioral Health.
Specialty Practices will be going live with EVC on Tuesday, January 23, 2024. To begin the transition and to introduce EVC to Specialty Practices, the EVC Project Team will be holding one-hour live webinars. Those dates are listed below.
Friday, 1/5/24 at 8am
Monday, 1/8/24 at 12pm
Wednesday, 1/10/24 at 3pm
More in-depth training webinars will be hosted by the PACE team. These webinars will specifically go over Epic Video Client’s clinical functionality. Those dates are listed below.
Friday, 1/12/24 at 12pm
Tuesday, 1/16/24 at 4pm
Wednesday, 1/17/24 at 3:30pm
Friday, 1/19/24 at 9:00am
Friday, 1/19/24 at 12pm
Monday, 1/22/24 at 4pm
We encourage users to sign up for both webinars. To sign up for these webinars as well as access materials/tipsheets we have prepared for patients, providers, and schedulers, please refer to our Connected Health Website.
For telehealth users that required customized telehealth solutions or special access to BlueJeans in the past, we encourage you to follow our Specialty Care workflow. If you find that Epic Video Client does not meet your needs, please reach out to either Andrew Ahn or Charles Bae (contact information below). We plan to have a non-Epic Video Client telehealth solution implemented by early March of next year.
Questions? Reach out to:
- Scott Border, Project Manager for Epic Video Client at cscott.border@pennmedicine.upenn.edu
- Charles Bae, Associate CMIO for Connected Health at charles.bae@pennmedicine.upenn.edu
- Andrew Ahn, CMIO Fellow at andrew.ahn@pennmedicine.upenn.edu
9/5/23 - Telemedicine Announcement
On August 8, 2023, Verizon announced that BlueJeans will be discontinued in the first half of 2024. BlueJeans will not be available after March 31, 2024. This announcement does not affect Penn Medicine’s operations or abilities to provide high quality telehealth care.
Since early 2023, Penn Medicine has been transitioning its telehealth capabilities from BlueJeans to Epic Video Client. Epic Video Client was selected to be Penn Medicine’s new telehealth platform due to its ability to provide a more integrated telehealth experience for patients and clinicians. The Connected Health Team has been working on timelines for a smooth transition with an expected completion date in early 2024. To date, Penn Medicine On Demand and Psychiatry have been using Epic Video Client.
The Connected Health Team will reach out to your department with more department-specific transition timelines in the upcoming weeks. No action is needed from clinicians or administrators at this time. We will ensure that the change to Epic Video Client is smooth for both patients and clinicians.
Additional considerations:
-
The transition to Epic Video Client will take place by department.
-
Switchboard will continue to be available as a patient communications and appointment coordination tool. You will no longer need to use Switchboard to launch a virtual visit.
Questions? Reach out to:
-
Christina O’Malley, Director of Network Telemedicine christina.omalley@pennmedicine.upenn.edu
-
Charles Bae, Associate CMIO for Connected Health charles.bae@pennmedicine.upenn.edu
-
Ray Rollins, Director for Room Technology rrollins@pennmedicine.upenn.edu
4/26/23 - 2-Year Extension of Medicare Telehealth Flexibilities
On December 29, 2022, President Biden signed the Consolidated Appropriations Act of 2023, which includes several provisions impacting telehealth, including a 2-year extension of many COVID-19 telehealth flexibilities. In a budget bill passed previously for FY 2022, Congress had included a 151-day extension after the end of the public health emergency (PHE) for some COVID-19 telehealth flexibilities. However, with the passage of the Consolidated Appropriations Act of 2023, the following Medicare telehealth flexibilities will now last until December 31, 2024:
- Expanding originating and geographic site to include anywhere the patient is located, including the patient’s home (as long as the provider is licensed in that state);
- Expanding eligible practitioners qualified to furnish telehealth services, including occupational therapists, physical therapists, speech-language pathologists and audiologists;
- Delaying the in-person requirement for mental health services furnished through telehealth;
- Extending coverage and payment for audio-only telehealth services;
- Extending the Acute Hospital Care at Home (AHCAH) initiative; and requiring the HHS Secretary to publish a report comparing AHCAH programs with traditional inpatient care delivery;
- Extending the ability to use telehealth services to meet the face-to-face recertification requirement for hospice care;
- Extending the ability for federally qualified health centers (FQHCs) and rural health clinics (RHCs) to furnish telehealth services.
A notable exclusion from this 2-year extension is the Ryan Haight waiver, which has allowed remote prescription of clinically appropriate controlled substances. This waiver is still scheduled to expire with the end of the PHE, which is currently active until at least April 2023.
The Connected Health team will monitor for additional guidance, such as CMS-issued FAQ documents.
QUESTIONS?
Reach out to the Connected Health team: PennConnectedHealth@pennmedicine.upenn.edu
4/13/23 - Telehealth & Virtual Supervision of Residents/Fellows
Additional details and information about some special circumstances are available at these links.
Note: We do not qualify as a “rural area” that allows exemptions as we are in a metropolitan statistical area or MSA
Resident Supervision Requirements Under Medicare (aamc.org)
MLN006347 – Teaching Physicians, Interns, & Residents Guidelines (cms.gov)
Details: Primary Care Exception
Although under Medicare rules residents are typically supervised in-person during the critical or key portions of the service by a teaching physician, the “primary care exception” allows residents (after completing six months of residency) to furnish office/outpatient evaluation and management (E/M) visit codes of lower and mid-level complexity (99201, 99202, 99203, 99211, 99212, 99213 and annual wellness visits (HCPCS G0402, G0438, G0439) without the presence of a teaching physician. The teaching physician must be immediately available onsite to provide the necessary direction and can only supervise four residents at a time. Under this exception, the teaching physician must also review the patient’s medical history, physical examination, diagnosis, and record of tests and therapies during or immediately after each visit. The teaching physician must have no other responsibilities at the time the residents are being supervised, assume management responsibility for the beneficiaries seen by the residents, and ensure that the services furnished are appropriate.
04/22/22 – IBC telemedicine reimbursement update
On March 1, 2022 IBC notified all Network Providers, including Penn Medicine, that effective 6/1/2022, reimbursement for telemedicine services provided to IBC Commercial (non-Medicare Advantage) Members/Patients in accordance with the 7/1/2021 Medical Coverage Policy for Telemedicine Services will be reduced by 15% of the established contracted rate. This reimbursement change will not apply to IBC Medicare Advantage products or behavioral health services.
The Penn Medicine Managed Care Contracting office is working closely with IBC on potential opportunities to mitigate the impact of this policy change. We will keep the health system informed as progress is made. In the meantime, this policy will apply to Penn Medicine and reimbursement reductions will be applied for dates of service beginning on June 1, 2022.
Click here to download this memo as a PDF.
04/20/22 – IBC commercial patients - stop non-parity telephone E/M codes
The purpose of this communication is to inform all Penn Medicine Physician Providers to stop performing and billing non-parity telephone E/M codes (99441 – 99443) for IBC Commercial** patients.
**These services are able to be provided to IBC Medicare Advantage patients since IBC follows Medicare guidelines and the non-parity telephone E/M codes are covered for the duration of the PHE.
Please share this information with your clinical and administrative leadership.
BACKGROUND
- IBC issued a Commercial (non-Medicare Advantage) Medical Coverage Policy for Telemedicine Services effective 7/1/2021. The policy provides details on which services are covered and eligible for reimbursement via telemedicine, and which are not.
- At the time the new policy was published, Penn Medicine felt it was unclear if IBC was covering/reimbursing the non-parity telephone E/M codes (99441 – 99443).
- Therefore, Managed Care Contracting requested clarification and received email confirmation indicating that the non-parity telephone E/M codes (99441 – 99443) were covered and eligible for reimbursement.
- After receiving claim denials for these services and raising concerns to IBC, Penn Medicine was notified that we had been misinformed; the non-parity telephone E/M codes are in fact neither covered nor eligible for reimbursement after 7/1/2021.
- We have been disputing this with IBC for months as we firmly believe their 7/1/2021 Commercial policy remains misleading.
- We have been unable to convince IBC of the flaw in their policy, and for this reason we believe it is important to stop performing and billing non-parity telephone E/M codes (99441 – 99443) for IBC Commercial patients.
- We will continue to pursue payment for the non-parity telephone E/M codes (99441 – 99443) provided to IBC Commercial patients up to this point as Penn Medicine was acting on the guidance provided by IBC.
- Below is a summary table that compares the Covid-19 period coverage to the new 7/1/2021 permanent Commercial policy coverage. IBC continues to pay at parity to in person office visits for all telemedicine services in the policy until 5/31/2022. A separate communication is forthcoming about the reimbursement reductions scheduled for 6/1/2022.
Click here to download this memo as a PDF.
01/11/22 – NJ telemedicine flexibilities extended
In response to the latest COVID-19 wave, telemedicine flexibilities have been extended in New Jersey. Penn Medicine practitioners who are based in Pennsylvania may continue to provide telemedicine across state lines into New Jersey for established patients only. Out-of-state telemedicine New Patient Visits are not permitted at this time. See details below:
- Practitioners without a temporary or permanent New Jersey license can have telemedicine visits with established patients located in New Jersey until May 11th, 2022. This timeline may be extended further with additional extensions of the New Jersey Public Health Emergency (PHE) and State of Emergency (SOE).
- Practitioners in the Group 2 license category with Temporary Emergency Reciprocity Licenses (TERLs) will have TERLs extended through June 30th, 2022. A TERL offers license reciprocity for both in-person and virtual care with patients located in New Jersey. Additionally, New Jersey will continue to accept new TERL applications from Group 2 practitioners while the program remains active.
- Group 2 practitioners include: Advanced practice nurse, licensed social worker, doctor of osteopathy, home health aide, licensed practical nurse, licensed alcohol and drug counselor, licensed clinical social worker, marriage and family therapist, medical doctor, professional counselor, psychoanalyst, psychologist, registered professional nurse, and respiratory care practitioner.
With the exception of the updated New Jersey telemedicine flexibility end dates outlined above, Penn Medicine’s existing out-of-state telemedicine guidance remains the same. You can always contact our team at PennConnectedHealth@pennmedicine.upenn.edu
Click here to download this memo as a PDF.
06/25/21 – Important IBC telemedicine update
The IBC permanent Commercial Telemedicine Services Policy will go into effect on 7/1/2021. There is no change at this time to the coverage for Medicare Advantage members. There is no change at this time to the expected reimbursement for telemedicine services (parity with in person visits). Coverage applies when:
- Performed by a participating provider* licensed in the State in which the individual originates the telemedicine encounter, and
- Delivered via HIPAA compliant system:
- Interactive, synchronous (real-time) two-way audio & video
- Asynchronous telecommunication (store and forward transmission) in conjunction with a synchronous audio interaction (telephone call) for Optometry, Ophthalmology and Dermatology ONLY
- Telephone communication (audio only/telephone call) for Clinical Genetics and Medical Genetics ONLY
* Certain specialties not eligible for telemedicine (e.g. Radiology, Respiratory Therapy, etc.)
More detail can be found at the links below:
- Click here for the IBC Commercial Telemedicine Coverage Policy in effect July 1, 2021
- Click here for the IBC Medicare Advantage Telemedicine Coverage Policy in effect from March 6, 2020 through the duration of the Federal Public Health Emergency.
- Click here for the IBC Commercial Telemedicine Coverage Policy in effect from March 6, 2020 to June 30, 2021.
Archived Guidance
07/19/21 – NJ telemedicine policy guidance
Last week, Penn Medicine issued updated guidance about offering out of state telemedicine visits to patients who are located in New Jersey. We do not recommend cancelling already scheduled patient visits or interrupting care. However, you should stop scheduling additional New Jersey telemedicine visits until you have:
- Extended your temporary emergency reciprocity license (TERL) by applying for a permanent New Jersey license or you have received your permanent New Jersey license, AND
- You have obtained a leasing agreement with Clinical Healthcare Associates of New Jersey (CHCA).
The Connected Health team would like to provide additional information to support interpretation of this guidance for practitioners.
- What actions do I need to take and when to…
- Obtain NJ licensure? New Jersey requires providers practicing their profession in New Jersey to be licensed by the applicable professional board. If you intend to provide patient care using telemedicine in New Jersey, you must obtain a New Jersey license. You can access your respective Board’s application by clicking here. If you have not already started this process, you must do so now. This can be a time-consuming process and can take several months.
- Obtain a leasing agreement with CHCA? If you have applied for an extension of your TERL or already have a permanent New Jersey license, you need to work with your Department or Division administrator to complete the CHCA leasing process. This process is applicable to physicians, advanced practice providers and other providers that bill for their services. Click here for more information.
- Can I offer telemedicine to patients located in New Jersey now…
- If I have an active New Jersey emergency license? Yes. Your TERL will allow you to provide telemedicine visits until it expires. If you are a Group 2 emergency license holder, you have until July 31st to apply for a permanent license if you would like your TERL to be extended until December 31st. If you have a TERL, you can start the CHCA leasing process now.
- If my emergency license has expired and I do not have a permanent New Jersey license or I do not have a leasing agreement with CHCA? In order to minimize the disruption to patient care, we will allow you to see already scheduled telehealth visits through December 31, 2021. After that date, you must either convert those visits to in-person visits or transfer that care to one of your New Jersey licensed colleagues. If you intend to continue practicing telemedicine with patients located in New Jersey after December 31st, you must have a permanent New Jersey license and obtain a CHCA leasing agreement.
- What about post-op visits? According to New Jersey law, scheduled post-op telehealth visits with patients located in New Jersey who had surgery in Pennsylvania should be handled by New Jersey licensed providers and in accordance with the above guidance.
- How does this guidance impact staff such as registered nurses?
- According to New Jersey law, New Jersey licensure is required if directing care in a scheduled patient-facing interaction. Penn Medicine is performing an analysis to determine which clinical staff roles and activities will require New Jersey licensure and will follow up with an update soon.
Click here to download this memo as a PDF.
07/12/21 – Penn Medicine supports the continued use of telehealth
Dear Penn Medicine clinicians and staff,
Penn Medicine is committed to supporting the continued use of telehealth services where legally and clinically appropriate to increase access and meet our patients where they are, in line with our Penn Medicine Team Goals.
Telehealth-related waivers instated under the Public Health Emergency (PHE) have been extended beyond the end of the PHEs in both Pennsylvania and New Jersey and are still in effect through at least 09/30/21 in both states. HHS is anticipated to renew the Federal PHE on 07/20/21 through the end of the calendar year. The Connected Health team is working to develop a comprehensive post-Public Health Emergency policy, and details are forthcoming.
All major payers continue to cover telehealth services at parity. Medicare MAPs payment for telehealth continues to be approximately $96 less per patient.
- Medicare is anticipated to extend expanded coverage through the end of the calendar year
- IBC rolled out permanent telemedicine coverage for Commercial members on 07/01/21
- Aetna’s expanded coverage is in effect until further notice
- PA Medicaid Plans coverage is in line with Pennsylvania telehealth waivers
- Horizon BCBS of NJ’s expanded coverage is in line with New Jersey telehealth waivers
As the policy and reimbursement landscape evolves, the Connected Health Team will continue to provide the latest information. We are available to address questions and concerns at PennConnectedHealth@pennmedicine.upenn.edu.
Click here to download this memo as a PDF.
07/07/21 – Important Update About Personal Penn Medicine BlueJeans Account
Dear Penn Medicine BlueJeans user,
Thank you for your collaboration as we continually improve telehealth offerings and security throughout our health system. As we have previously communicated, to ensure optimal telehealth workflows and to meet best security and privacy standards, all BlueJeans meetings for clinical care/telehealth appointments will be required to be initiated through the Switchboard platform or, at LGH, through PennChart.
To ensure compliance with this, we will be deactivating and removing all individual Penn Medicine BlueJeans accounts on Wednesday, July 21, including yours.
This means that you will no longer be able to create/schedule meetings directly from the BlueJeans application. All BlueJeans meetings used for telehealth appointments will be generated and managed through the Switchboard platform or, at LGH, PennChart.
Individual Penn Medicine BlueJeans accounts are identified by a Penn Medicine logo on the BlueJeans account screen or meeting window. They are logged into through pennmedicine.bluejeans.com and have meeting URLs beginning with pennmedicine.bluejeans.com.
University of Pennsylvania BlueJeans accounts (identified by Penn logo on meeting screens and logged into with PennKey along with meeting URLs of upenn.bluejeans.com) will be unaffected by this change.
If you have been using your own individual Penn Medicine BlueJeans account for videoconferencing, you should consider taking steps to prepare for that account being deactivated please see this tip sheet for guidance. The tip sheet also describes the process for requesting an exception to maintain your individual account — exceptions will be granted in limited, appropriate circumstances.
Please continue to contact our help desk at 215-662-7474 or by placing a ticket via the IS service portal through the telemedicine support form if you have any questions or concerns. Our team members at Penn Medicine Connected Health look forward to supporting you and ensuring that your virtual visit needs are met through our telehealth platforms and that other needs you may have are met through approved platforms.
Thank you,
Penn Medicine Connected Health
Click here to download this memo as a PDF.
03/23/21 – Out of state new patient visits and telehealth
Why is Penn Medicine no longer authorizing out of state new patient visits for telehealth?
Scheduling of new patient out of state telehealth visits in a community setting (excluding those provided in a hospital setting e.g. inpatient or emergency room) has been disabled in PennChart due to clarifications in state laws and changes to state licensure waivers associated with the public health emergency. These changes include out of state licensure as well as out of state laws/regulations relating to employment, medical board supervision and billing.
What about out of state telehealth new patients that are already on my schedule?
Already scheduled telehealth NPVs may remain on provider schedules.
Who does this impact?
This change impacts any clinician who requires an out of state license and/or bills including physicians, APPs, nurses, genetic counselors, social workers, pharmacists, PT/OT and dieticians.
What if I am licensed in the state where the patient resides or is physically located at the time of the telehealth NPV?
Being licensed in the state where the patient resides or is located at the time of the telehealth visit is only one step in the process. Depending on the state where the visit is to occur (determined by the patient’s location at the time of the visit) there may be other state laws/regulations that require further review and steps we need to take to assure continuing compliance. It does not matter where the provider is physically located at the time of the visit. We are actively working with Information Services, Revenue Cycle and Schedgistration to create automated logic to address these required steps to enable us to resume out of state telehealth NPVs where legally permitted.
What about out of state established patients? What constitutes an established relationship?
This new guidance applies to NEW patient telehealth visits only. During the public health emergency, this guidance does not impact out of state established patients. An established patient is specific to the individual clinician NOT the practice.
What about our existing relationships and affiliations where we provide telemedicine services e.g. telestroke, teleICU or telegenetics to out-of-state hospital patients?
This new guidance does not impact existing telemedicine service and affiliation agreements that we have in place with out of state hospitals (i.e. Shore Medical, Bayhealth). Providers still need to be licensed in the state where the visit occurs and need to abide by the contractual relationships e.g. credentialing, etc.
What about reviewing the FSMB licensure grid prior to scheduling?
For the time being while we operationalize changes to our work flow, there is no need to research the FSMB. Scheduling of community based telehealth NPVs should stop while we work to create automated scheduling logic.
Click here to download this memo as a PDF.