Telehealth Practice

Encourage the Appropriate Use of Telehealth

In response to the COVID-19 public health emergency (PHE), CMS loosened its telehealth rules and expanded the types of telehealth services that are reimbursable by Medicare. There continues to be widespread support for these telehealth flexibilities as Congress has passed legislation to extend them on numerous occasions since the end of the PHE.  There also are ongoing efforts to make these telehealth flexibilities permanent. Although telehealth utilization has leveled off as in-person visits have rebounded, there has been a paradigm shift where the healthcare system now relies more on telehealth. Telehealth remains nearly two times higher than pre-pandemic levels, with more than one in ten (12.7%) eligible beneficiaries receiving a telehealth service in the final quarter of 2023.^[i]

While ACOFP supports the use of telehealth, we also firmly believe that in-person care is the gold standard for care and that telehealth is a tool to improve care delivery when in-person care is not possible. We believe it is critical that there are safeguards against the potential for telehealth to inadvertently disrupt existing physician-patient relationships and care coordination. Telehealth-only providers may have limited encounters with patients and may not appropriately coordinate with family physicians so that this trend could result in worsening medical conditions and poor health outcomes.

ACOFP believes telehealth is best used for established patients, and the primary care physician should coordinate care for patients, including care furnished via telehealth. We want to avoid situations in which telehealth is used as a replacement for in-person care delivered over time, as this is an important element of chronic condition management often performed by osteopathic family physicians. Further, while telehealth is convenient and necessary at times, it also may result in large national telehealth companies providing fragmented care with no coordination with a patient’s primary care provider. Thus, ACOFP urges caution when establishing telehealth policies.

Advocacy Positions:

• Require physicians who practice telehealth outside of interstate compacts to be licensed in the state in which they are practicing telehealth.
• Ensure accountability for out-of-state telehealth providers to safeguard patient safety and quality of care.
• Ensure care provided via telehealth is properly coordinated with the patient’s primary care physician.[1] [2] [3] [4] 
• Allow continued reimbursement for audio-only telehealth services in a manner that protects program integrity.
• Establish appropriate rules to curb fraud and abuse and protect patients from unnecessary charges.
• Rely on data and evidence to develop a telehealth coverage policy that ensures patients are receiving the highest quality care possible.
• Allow patients to use telehealth from their home by reforming or eliminating originating site requirements.
• Establish payment rates that reflect the resources and expertise necessary to deliver high-quality care via telehealth.
• Ensure that family physicians have sufficient resources to invest in new technologies to provide effective telehealth services.
  
  

  ^[i] Cottrill A, Cubanski J, Neuman T. What to Know About Medicare Coverage of Telehealth. KFF. October 2, 2024. Accessed January 25, 2026. https://www.kff.org/medicare/what-to-know-about-medicare-coverage-of-telehealth/