Telehealth Issues

Telehealth (also referred to as telemedicine and telepractice) refers to the use of electronic communication and information technologies by health care professionals to provide or support interactive, long-distance clinical care to a patient in another location. Telehealth includes practicing by telephone or facsimile, or using more interactive technologies such as Internet connections and advanced video conferencing systems.

The increase in telehealth and the new technologies that support it have created a great deal of federal and state government action, from coverage and reimbursement of services and providers to licensure of electronic practice across state borders. The AARC tracks these efforts to ensure representation of respiratory therapy services and respiratory therapists in the development of telehealth policies.

We will keep this page updated as more information becomes available.

AARC Requests RTs Be Included as Teleconsultants in HR 1344

November 4, 1999

The Honorable Jim Nussle
United States House of Representatives
303 Cannon House Office Building
Washington, DC 20515

RE: The Triple-A Rural Health Improvement Act of 1999 (H.R. 1344)

Dear Representative Nussle:

I am writing on behalf of the American Association for Respiratory Care (AARC) regarding H.R. 1344, a bill to promote access to health care services in rural areas. The AARC is a professional association representing over 34,000 respiratory therapists (RTs) nationwide. We recommend that H.R. 1344 be amended to include respiratory therapists in the definition of "practitioner" under Title V, Subtitle A, Sec. 501(a)(2) of this proposal.

Telehealth is becoming a viable health care option for Medicare beneficiaries in rural areas. As a health care professional from a frontier state, I have seen first hand the difference telehealth could make to respiratory patients living far from health facilities. However, without the inclusion of respiratory therapists, many Medicare beneficiaries suffering from emphysema, Chronic Obstructive Pulmonary Disease (COPD), and other respiratory illnesses may not benefit from the care possible through telehealth.

Respiratory therapy is a highly specialized allied health discipline focused on the management and treatment of lung disease and illness. Respiratory therapists treat patients with acute and complex respiratory problems in a broad spectrum of settings, including the home. When the Medicare program was initiated, the technology was not present to treat Medicare beneficiaries suffering from lung diseases and other respiratory illnesses in their homes. Today, this technology is available and can be utilized through telehealth to initiate, conduct, and modify prescribed respiratory therapy treatments.

Through telehealth, for example, Medicare beneficiaries receiving oxygen therapy could have their care plans assessed and modified by respiratory therapists. Oxygen concentrators can be connected through telephone lines from the patient’s home to a hospital’s respiratory therapy department or to a home care agency. Respiratory therapists could then monitor the patient to determine if he or she is receiving the correct amount of liter flow and oxygen percentage. Not only would patients receive needed treatment, but Medicare dollars may be spent more economically when therapists’ assessments lead to the determination that a patient has improved and no longer requires oxygen.

Respiratory therapists are the only skilled health care professionals who receive comprehensive formal education, clinical training, and validated competency testing in respiratory therapy. A 1994 curriculum comparison study by the Indiana University Center for Survey Research (enclosed) indicates that respiratory therapists spend ten times more classroom hours on respiratory therapy subjects, such as oxygen therapy, than do nurses in baccalaureate programs.

In addition, a 1999 study by Muse & Associates (enclosed) comparing residents in skilled nursing facilities (SNFs) who received care from a respiratory therapist versus those who did not resulted in several dramatic findings:

This study highlights the savings in lives and costs that may be derived from using respiratory therapists to deliver care to chronically ill respiratory patients. Similar savings may be possible through using respiratory therapists as practitioners of telehealth.

Telehealth can provide access to health care for respiratory patients in rural areas where little has been available. However, telehealth may not reach this goal if patients cannot access the expertise of respiratory therapists through teleconsultations. The AARC, in its comments to HCFA on this provision under the BBA, outlined several areas in Medicare policy in which respiratory therapists could be utilized as teleconsultants. I have enclosed these comments for your review.

The AARC appreciates this opportunity to make this recommendation. If you or your staff have any questions, please contact Jill Eicher, AARC Director of State Government Affairs, at 703/548-8538.

Sincerely,
Dianne N. Kimball, RRT
President

Enclosures

cc: The Honorable Robert B. Aderholt, The Honorable Ray LaHood, The Honorable Thomas H. Allen, The Honorable Tom Latham, The Honorable Brian Baird, The Honorable James A. Leach, The Honorable Richard H. Baker, The Honorable Ron Lewis, The Honorable John Elias Baldacci, The Honorable Frank D. Lucas, The Honorable Tammy Baldwin, The Honorable Frank Mascara, The Honorable James Barcia, The Honorable John M. McHugh, The Honorable Bill Barrett, The Honorable Scott McInnis, The Honorable Charles F. Bass, The Honorable Mike McIntyre, The Honorable Doug Bereuter, The Honorable David Minge, The Honorable Marion Berry, The Honorable Jerry Moran, The Honorable Sanford D. Bishop Jr., The Honorable George R. Nethercutt Jr., The Honorable Henry Bonilla, The Honorable Robert W. Ney, The Honorable Leonard L. Boswell, The Honorable Charlie Norwood, The Honorable Rick Boucher, The Honorable James Oberstar, The Honorable Kevin Brady, The Honorable James W. Olver, The Honorable Robert Brady, The Honorable Ed Pastor,The Honorable Dave Camp, The Honorable Collin C. Peterson, The Honorable Eva M. Clayton, The Honorable John E. Peterson, The Honorable James E. Clyburn, The Honorable Thomas E. Petri, The Honorable Larry Combest, The Honorable David D. Phelps, The Honorable Gary A. Condit, The Honorable Charles Pickering, The Honorable John Cooksey, The Honorable Earl Pomeroy, The Honorable Jerry F. Costello, The Honorable Nick J. Rahall II, The Honorable Robert E. Cramer Jr., The Honorable Bob Riley, The Honorable Pat Danner, The Honorable Ciro Rodriguez, The Honorable Peter A. DeFazio, The Honorable Jim Ryun, The Honorable Jay Dickey, The Honorable Max Sandlin, The Honorable Calvin Dooley, The Honorable Bob Schaffer, The Honorable Chet Edwards, The Honorable Pete Sessions, The Honorable Jo Ann Emerson, The Honorable Ronnie Shows, The Honorable Lane Evans, The Honorable Michael K. Simpson, The Honorable Eni F. H. Faleomavaega, The Honorable Ike Skelton, The Honorable Martin Frost, The Honorable Lamar Smith, The Honorable Wayne T. Gilchrest, The Honorable Debbie Stabenow, The Honorable Paul E. Gillmor, The Honorable Charles W. Stenholm, The Honorable Charles A. Gonzalez, The Honorable Bart Stupak, The Honorable Bart Gordon, The Honorable John E. Sweeney, The Honorable Mark Green, The Honorable Charles H. Taylor, The Honorable Ralph Hall, The Honorable William Thornberry, The Honorable Alcee L. Hastings, The Honorable Jim Turner, The Honorable J.D. Hayworth, The Honorable Tom Udall, The Honorable Wally Herger, The Honorable Greg Walden, The Honorable Rick Hill, The Honorable James T. Walsh, The Honorable Earl F. Hilliard, The Honorable Wes Watkins, The Honorable Ruben Hinojosa, The Honorable Don Young, The Honorable Peter Hoekstra, The Honorable Darlene Hooley, The Honorable Kenny C. Hulshof, The Honorable Ron Kind, The Honorable Jack Kingston, The Honorable Jim Kolbe, The Honorable John J. LaFalce

AARC Asks Senator Conrad to Include RTs as Teleconsultants in S. 770

October 22, 1999

The following letter to Sen. Kent Conrad (D-ND) recommends that his bill on telehealth (S. 770) be amended to include respiratory therapists as "teleconsultants." Sen. Conrad's bill would amend several provisions regarding telehealth that first appeared in the Balanced Budget Act (BBA) of 1997. Under the BBA, a provision was established in which the services of certain "teleconsultants" would be covered and reimbursed under the Medicare program. Respiratory therapists were not included as teleconsultants and the AARC made this recommendation initially to HCFA in our August 21, 1998, commments outlined below. Sen. Conrad's bill would amend this provision to add more professions as teleconsultants and the AARC, again, adovcates the inclusion of respiratory therapists on that list.

  October 18, 1999

The Honorable Kent Conrad
United States Senate
530 Hart Senate Office Building
Washington, DC 20510

RE: The Comprehensive Telehealth Act of 1999 (S. 770)

Dear Senator Conrad:

I am writing on behalf of the American Association for Respiratory Care (AARC) regarding S. 770, a bill to provide Medicare reimbursement for telehealth services. The AARC is a professional association representing over 34,000 respiratory therapists (RTs) nationwide. We recommend that S. 770 be amended to include respiratory therapists as teleconsultants under this proposal.

Telehealth is becoming a viable health care option for Medicare beneficiaries in rural areas. As a health care professional from a frontier state, I have seen first hand the difference telehealth could make to respiratory patients living far from health facilities. However, without the inclusion of respiratory therapists as teleconsultants, many Medicare beneficiaries suffering from emphysema, Chronic Obstructive Pulmonary Disease (COPD), and other respiratory illnesses may not benefit from the care possible through telehealth.

Respiratory therapy is a highly specialized allied health discipline focused on the management and treatment of lung disease and illness. Respiratory therapists treat patients with acute and complex respiratory problems in a broad spectrum of settings, including the home. When the Medicare program was initiated, the technology was not present to treat Medicare beneficiaries suffering from lung diseases and other respiratory illnesses in their homes. Today, this technology is available and can be utilized through telehealth to initiate, conduct, and modify prescribed respiratory therapy treatments.

Through telehealth, for example, Medicare beneficiaries receiving oxygen therapy could have their care plans assessed and modified by respiratory therapists. Oxygen concentrators can be connected through telephone lines from the patient’s home to a hospital’s respiratory therapy department or to a home care agency. Respiratory therapists could then monitor the patient to determine if he or she is receiving the correct amount of liter flow and oxygen percentage. Not only would patients receive needed treatment, but Medicare dollars may be spent more economically when therapists’ assessments lead to the determination that a patient has improved and no longer requires oxygen.

Respiratory therapists are the only skilled health care professionals who receive comprehensive formal education, clinical training, and validated competency testing in respiratory therapy. A 1994 curriculum comparison study by the Indiana University Center for Survey Research (enclosed) indicates that respiratory therapists spend ten times more classroom hours on respiratory therapy subjects, such as oxygen therapy, than do nurses in baccalaureate programs.

In addition, a 1999 study by Muse & Associates (enclosed) comparing residents in skilled nursing facilities (SNFs) who received care from a respiratory therapist versus those who did not resulted in several dramatic findings:

This study highlights the savings in lives and costs that may be derived from using respiratory therapists to deliver care to chronically ill respiratory patients. Similar savings may be possible through using respiratory therapists as teleconsultants.

Telehealth can provide access to health care for respiratory patients in rural areas where little has been available. However, telehealth may not reach this goal if patients cannot access the expertise of respiratory therapists through teleconsultations. The AARC, in its comments to HCFA on this provision under the BBA, outlined several areas in Medicare policy in which respiratory therapists could be utilized as teleconsultants. I have enclosed these comments for your review.

The AARC appreciates this opportunity to make this recommendation. If you or your staff have any questions, please contact Jill Eicher, AARC Director of State Government Affairs, at 703/548-8538.

Sincerely,
Dianne N. Kimball, RRT
President

Enclosures

cc: The Honorable Thomas Daschle
The Honorable Tom Harkin
The Honorable Daniel Inouye
The Honorable Barbara Mikulski
The Honorable Paul Wellstone

The AARC sent the following letter to the Health Care Financing Administration (HCFA) in response to a call for comments on the proposed rule regarding payment for professional consultations via interactive telecommunication systems in rural areas. We stated our position very strongly that telemedicine would be less than effective for Medicare patients if HCFA omits reference to respiratory therapists in its policy.

The AARC recognizes that although telemedicine is still a fairly new technology, the potential benefits it offers patients are very clear. However, we believe it is also clear that in order for telehealth to provide the optimum benefit to Medicare beneficiaries, respiratory therapists must be allowed for in HCFA's telehealth policy. A growing number of respiratory therapists across the country are getting involved in patient care as teleconsultants, and we view that as a necessary trend if telemedicine is truly going to provide the best possible health care.

August 21, 1998

Health Care Financing Administration
Department of Health and Human Services
Attention: HCRA-1906-P
P.O. Box 26676
Baltimore, MD 21207-0519

RE: Payment for Teleconsultations in Rural Health Professional Shortage Areas

Dear Madam Secretary:

The American Association for Respiratory Care (AARC) welcomes the opportunity to comment on the proposed rule regarding payment for professional consultations via interactive telecommunication systems in rural health professional shortage areas. The AARC is a non-profit 37,000 member professional association comprised primarily of respiratory therapists from across the country.

Respiratory therapists care for patients ranging from the premature infant whose lungs are underdeveloped, to the elderly patient whose lungs are diseased. Individuals who suffer from emphysema and lung cancer; children who suffer from asthma or cystic fibrosis; and patients of all ages who require the use of a ventilator to breathe are often cared for the respiratory therapist.

The AARC supports efforts to bring health care access via telehealth to underserved areas. We also support current Medicare policy that provides some coverage for telemedicine for applications where, under conventional health care delivery, medical services do not require face-to-face contact between patient and physician.

Furthermore, the AARC supports the reimbursement provisions in the Balanced Budget Act (BBA) of 1997 that go a step further by providing reimbursement to other telemedicine providers, thus providing access to specialty care that is usually absent in rural areas.

Telemedicine Should Utilize the Expertise of Respiratory Therapists

Although not listed as a practitioner under Section 1842(b)(18)(C) of the BBA, respiratory therapists should be included in order to utilize their expertise in providing respiratory therapy evaluations via teleconsultations. Our rationale for this recommendation is based on the fact that respiratory therapists are the only skilled health care practitioners who receive comprehensive formal education, clinical training, and validated competency testing in respiratory care services.

Respiratory therapistsí education focuses on clinical assessment, pathophysiology, diagnostic testing, therapy, post-surgical care, pediatrics, patient education, infectious disease and mechanical ventilation. Moreover, in order to become credentialed, respiratory therapists must pass a rigorous examination administered by the National Board for Respiratory Care (NBRC). The NBRC examination is the only examination that tests the competency of health professionals to render respiratory care services.

Given that respiratory therapists undergo more advanced, specialized training, education, and competency testing focused on respiratory care than any other health professional, does it make sense not to utilize their services through telemedicine for Medicare beneficiaries in rural areas?

Respiratory Therapists are Experienced Teleconsultants

In many rural areas of the country, respiratory therapists are already serving as teleconsultants providing patient evaluations and recommending therapy necessary for that patient. In Bismarck, North Dakota, for example, the respiratory care department at St. Alexius Medical Center is part of a demonstration project that has protocols to handle telehealth consultations with area nursing homes. Physicians in rural areas who are not well versed in respiratory care protocols and who do not have respiratory therapists at their facilities would rely on the evaluations provided by respiratory therapists through teleconsultations.

In addition, there are several areas under current Medicare policy that can utilize the respiratory therapistís expertise through teleconsultations, including the following:

The AARC acknowledges that the proposed rule requires that the telecommunications technology allow the consulting practitioner to control an interactive medical examination of the patient. However, the AARC recommends that the Health Care Financing Administration recognize the value of other forms of teleconsultations to patient care.

For example, other diagnostic areas where respiratory care could be utilized via teleconsultations include oxygen concentrators that are connected through telephone lines from the patients to a respiratory care department. Respiratory therapists could then monitor the patient to determine if the correct amount of liter flow and oxygen percentage were being provided to the patient. Another area is monitoring patients for nocturnal sleep studies via telephone lines to determine whether CPAP is required based on oxygen titration testing.

AARC Supports HCFAís Efforts to Bring Telemedicine to Underserved Areas

Telemedicine now has the potential to make a difference in the lives of many Americans. Telemedicine can improve the delivery of health care in America by bringing a wider range of services to communities and individuals in rural areas. In remote rural areas, telemedicine can mean access to health care where little had been available. In emergency cases, this access can mean the difference between life and death. For those in need of specialty care, telemedicine availability can be critical.

Sincerely,
Sam P. Giordano, MBA, RRT
Executive Director
American Association for Respiratory Care

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