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Frequently Asked Questions

Table of Contents

Definition of Telemedicine

Texas Medical Board Rules for Telemedicine

What about Credentialing & Privileging?


Telemedicine Defined by the American Telemedicine Association

Telemedicine is the use of medical information exchanged from one site to another via electronic communications to improve patients' health status. Closely associated with telemedicine is the term "telehealth," which is often used to encompass a broader definition of remote healthcare that does not always involve clinical services. Videoconferencing, transmission of still images, e-health including patient portals, remote monitoring of vital signs, continuing medical education and nursing call centers are all considered part of telemedicine and telehealth.

Telemedicine is not a separate medical specialty. Products and services related to telemedicine are often part of a larger investment by health care institutions in either information technology or the delivery of clinical care. Even in the reimbursement fee structure, there is usually no distinction made between services provided on site and those provided through telemedicine and often no separate coding required for billing of remote services.

Telemedicine encompasses different types of programs and services provided for the patient. Each component involves different providers and consumers.


TMB Telemedicine Board Rules for Telemedicine

The Texas Medical Board (TMB) adopted proposed changes to the Telemedicine rules on April 10, 2015 and these rules will become effective June 3, 2015 once they are added into the register. Click the following to view these rule changes:
Proposed Changes for Telemedicine - Chapter 174.

To further explain the proposed changes to the TMB Telemedicine rules and how these rules will expand telemedicine opportunities in Texas, please view the April 14, 2015 press release



Final Rule Streamlines Telemedicine Credentialing & Privileging Process

The Centers for Medicare & Medicaid Services (CMS) issued a final rule on May 5, 2011, offering hospitals and critical access hospitals (CAHs) the option to streamline the credentialing and privileging process for physicians and non-physician practitioners providing telemedicine services. The revised guideline will allow small hospitals and CAHs to expand access to specialty patient care services provided by remote practitioners and receive those services from another Medicare-participating hospital or other distant-site telemedicine entity in a timely manner.

Telemedicine Defined

Telemedicine is defined in the final rule as “provision of clinical services to patients by practitioners from a distance via electronic communications. The distant-site telemedicine physician or practitioner provides clinical services to the hospital or CAH patient either simultaneously, as is often the case with teleICU services, or non-simultaneously, as may be the case with many teleradiology services.”Telemedicine is defined in the final rule as “provision of clinical services to patients by practitioners from a distance via electronic communications. The distant-site telemedicine physician or practitioner provides clinical services to the hospital or CAH patient either simultaneously, as is often the case with teleICU services, or non-simultaneously, as may be the case with many teleradiology services.”

“Simultaneous” telemedicine services are performed in real time, similar to medical services provided during a face-to-face encounter.

“Non-simultaneous” telemedicine services are requested by the patient’s attending physician or practitioner and may involve interpretation of diagnostic testing. The interpreting telemedicine practitioner does not assess the patient in real time, but transmits the interpretation results to the attending physician or practitioner for patient diagnosis or management.

A “distant-site telemedicine entity” is defined in the final rule as “one that (1) provides telemedicine services; (2) is not a Medicare-participating hospital (therefore, a non-Medicare-participating hospital that provides telemedicine services would be considered a distant-site telemedicine entity also); and (3) provides contracted services in a manner than enables a hospital or CAH using its services to meet all applicable CoPs, particularly those requirements related to the credentialing and privileging of practitioners providing telemedicine services to the patients of a hospital or CAH.”

Current Guidelines

Under the current condition of participation (CoP), all hospitals must credential and assess privilege for all physicians or non-physician practitioners who provide services to their patients, including telemedicine practitioners. The hospital’s governing body is responsible for accepting practitioners to its medical staff and granting privileges after thorough examination, verification of credentials and evaluation of specific criteria. CAHs that are members of a rural health network must follow a similar process, but also must maintain an agreement with another hospital that is a member of the same health network, a Medicare Quality Improvement Organization (QIO) or another qualified entity. The CAH credentialing and privileging process also requires assessment and approval of its medical staff by this outside entity. CMS recognized the process was burdensome and that small hospitals and CAHs might not have the resources or clinical expertise within their medical staff to evaluate and assign privileges to specialists providing telemedicine services.

Revised Guidelines

Effective July 2, 2011, the final rule revised sections of the CoP for hospitals and CAHs to allow the governing body (or responsible individual for CAHs) to accept the “credentialing and privileging decisions made by the distant-site telemedicine entity” for individual physicians or non-physician practitioners asked to provide telemedicine services. In addition, the governing body must obtain a written agreement specifying the distant-site entity as a “contractor of services” and stating the distant-site entity ensures all furnished services will comply with applicable CoP criteria for hospitals or CAHs.

There is an exception to the requirement for a CAH to have an agreement with one or more Medicare-participating providers or suppliers. The CoP now allows for an agreement with a distant-site, non-Medicare-participating entity providing telemedicine services. Specifically, the final rule says an agreement can exist “between a CAH and a distant-site telemedicine entity for the entity’s distant-site physicians and practitioners to provide telemedicine services to the CAH’s patients.”

Conclusion

The final rule for credentialing and privileging of telemedicine services is a significant advancement for specialty medical care providers, particularly rural hospitals and CAHs. Facilities considering implementing this streamlined process may experience initial cost in developing agreements with the distant-site telemedicine entity. Essentially, the benefits of expanding access to specialty services should outweigh any administrative cost.