03/23/2020
TELEMEDICINE -
Did you know that telemedicine is eligible for 340B use if under the correct circumstances. Patient Definition must still be met by an eligible "service" even if it takes place at an unregistered location.
Many entities are facing new circumstances never seen before. Telemedicine or remote medicine may be front and center as a care protocol for your patients.
HRSA has also posted updated clarification on other policy related matters that could be impacted by COVID-19.
https://www.hrsa.gov/opa/COVID-19-resources
Here's is the current FAQ approved by HRSA on the Apexus website.
Question Is telemedicine an eligible service to qualify for 340B drug pricing in a covered entity?
Answer In the case of eligible hospitals, the clinic at which the covered entity provides healthcare services must be an integral part of the hospital, listed as reimbursable on its Medicare cost report. In the case of all other covered entities, the patients must be provided healthcare services by the covered entities that are within the scope of the grant or other statutory basis for eligibility. The entity is responsible for meeting the definition of a patient. For more information on the definition of a patient please see October 24, 1996 (Vol.61, No.207, pp. 55156-5158) Final Notice Regarding Section 602 of the Veterans Health Care Act of 1992 Patient and Entity Eligibility (Definition of Patient). ftp://ftp.hrsa.gov/bphc/pdf/opa/FR10241996.htm.
To be eligible, you would want to be able to show that the care is documented in the entity EMR, the service(s) is covered under your scope (pediatrics, geriatrics, ID, etc.), (or rolls up to an eligible an registered site on your recently filed MCR ), the provider is employed or contracted, and the CE is billing for the service as you would any service at a registered location. (This is not absolutely required, but makes it more clear).
It is suggested adding this to the definition of an eligible patient in your approved policies.
The same logic applies to "remote medicine" if providing approved services by eligible providers (and retaining records of care), at a site that is not otherwise eligible (nursing home, private home, etc).
HRSA is working to keep 340B Program participants and stakeholders updated on the latest information regarding the coronavirus disease 2019 (COVID-19). All COVID-19 information related to the 340B Program will appear on this page, and we will update resources as they become available.
