Delores Di Re, a senior manager at Cohn Resnick who specializes in the health care field, said that the movement toward telehealth services during the pandemic represents not a temporary shift until things get back to normal, but a long-term change in the  field overall.

Speaking at the Foundation for Accounting Education's Health Care Conference Thursday, Di Re said that remote access to health care has exploded during the pandemic, as more patients grow hesitant about physically visiting their doctor's office. This rise has been enabled through a number of policy changes enacted at both the state and federal level that removed many of the restrictions on providing services in this way.

For instance, she said, the Office of Human Rights in the federal Department of Health and Human Services waived certain restrictions embedded in the Health Insurance Portability and Accountability Act (HIPAA) regulations, "saying they won't impose penalties for providers connecting with patients in good faith for the purpose of providing these telehealth encounters." The office also expanded the ways that doctors can connect with patients, allowing for telehealth sessions over widely available platforms, such as Facebook, Google Hangouts or Zoom, a practice that regulators had previously frowned upon.

Similarly, pre-pandemic, she said, "there were very stringent restrictions placed on Medicare both on the definitions of the originating site and the distance site, so the opportunity for payment was limited," given supervision requirements. Since the pandemic, though, the Commission on Medicare Services "said the supervision can be provided virtually," and so "theoretically the patient could be anywhere, and similar with providers."

The office also waived the requirement that telehealth services be offered only to existing patients, allowing providers to service new patients as well, and it also changed payment consent rules to say that consent is given once a virtual session is started (rather than before, when consent needed to be obtained prior to the appointment).

All these things have provided health care providers with unprecedented flexibility with remote services. Which, Di Re said, then raises the question "Well, how do I get paid?"

In this respect, she said, documentation is key, noting that none of the requirements in this area have changed. Providers still need to apply best practices in noting the start and end times of encounters, who was there (especially in dealing with minors), and the nature of the care, among other things.

"I feel strongly about this because this is all relatively new, and we are yet to be aware of any future audits that might take place and what may be required from providers," she said. "Again, this doesn't change documentation requirements and best practices the provider has been practicing when it was face-to-face. They just need to be mindful and do due diligence in virtual communications."

She noted this could create some logistical hurdles, depending on where the provider is. Practitioners who were slow to adopt telehealth may be challenged by integrating this documentation into their larger practice management system or health records system, particularly if they cannot physically access their place of work. On top of this are issues such as out-of-date software or connectivity issues.

One thing she said she has found very encouraging is the fact that there has been little to no change in the reimbursement rates for telehealth services compared to face-to-face services. For the most part, billing is the same, although in New York specifically, the rate is a little lower if a provider works only through audio, instead of audio-visual. Also, the time requirements for the same reimbursement amount changed for certain services, and there has also been some new restrictions on cost-rounding that will be retroactive to March 7. But despite this, she said, the transition has been relatively smooth, and she expects the models established during the pandemic will persist long after it's gone.

"I hope telehealth is here to stay in one form or another," she said. "It has to. I can't see this just going away. But we must look at more development if we are going to this new modality. How do we account for certain additions of work force? How do we recruit? How do we plan this out?" Despite these questions, she said, in today's day and age, "there is no reason for telehealth to not be adopted by any provider."