Telehealth Policy Trends in Medicaid

The Center for Connected Health Policy (CCHP) released its now biannual report on state telehealth policies and Medicaid. While many states are beginning to expand telehealth reimbursement, others continue to restrict and place limitations on telehealth-delivered services. Although each state’s laws, regulations, and Medicaid program policies differ significantly, certain trends are evident when examining the various policies. Live video Medicaid reimbursement, for example, continues to far exceed reimbursement for store and forward and remote patient monitoring (RPM).

However, over the past year, there has been a slight uptick in Medicaid policy allowing for store and forward as well as RPM reimbursement, although generally on a limited basis. For example, Connecticut is allowing for store and forward reimbursement for physician-to-physician email consultations (known as eConsult) exclusively, while Missouri has added store and forward and RPM reimbursement but limited it to specific specialties. Nevada recently incorporated store and forward reimbursement by noting they will cover asynchronous telehealth and lists no further limitations. Some states are veering away from standard definitions, such as Maryland, which now allows reimbursement of asynchronous dermatology, ophthalmology, and radiology, but excludes these specialties from the definition of store and forward. Other states have passed wide-ranging laws requiring telehealth reimbursement in their Medicaid program in recent years, but some Medicaid programs have yet to respond with official regulation or documentation in their provider manuals indicating they are indeed reimbursing services via telehealth. Other noteworthy trends include the addition of the home and schools as an eligible originating site in some states and the inclusion of teledentistry as a specialty qualifying for Medicaid reimbursement and/or required to be reimbursed by private insurers.

Additionally, some states have begun creating special exceptions or allowances to use telehealth for certain situations, such as Maryland allowing the home to be an originating site for the hearing impaired or Utah passing a private payer law but only for telepsychiatry. Laws and regulations allowing practitioners to prescribe medications through live video interactions have also increased as well as a few states even allowing for the prescription of controlled substances over telehealth within federal limits. This has mainly been a result of the opioid epidemic and the need to prescribe controlled substances used in medication-assisted therapy treatment.

Forty-nine states and the District of Columbia (DC) have some form of Medicaid reimbursement for telehealth in their public program. The only state that we determined did not have any written definitive reimbursement policy is Massachusetts. However, the extent of reimbursement for telehealth-delivered services is less clear in some states than others. For example, Iowa’s Medicaid program issued a broad regulatory statement confirming they do provide reimbursement for telehealth in 2016. This policy change came as a result of Iowa Senate Bill 505, which required the Department of Health and Human Services to adopt formal rules regarding their longstanding (although unwritten) policy to provide reimbursement for telehealth. However, the rule that was adopted simply states “in person contact between a provider and patient is not required for payment for services otherwise covered and appropriately provided through telehealth as long as it meets the generally accepted health care practices and standards prevailing in the applicable professional community.” Neither the legislation nor the rule provides a definition of telehealth, which leaves the policy vague and up for interpretation. Therefore, it is unclear whether store and forward or RPM services would fall under the umbrella of this telehealth policy.

Currently, 38 states and DC have laws that govern private payer telehealth reimbursement policies. Both Iowa and Utah passed telehealth private payer reimbursement legislation, although both laws don’t go into effect until January 1, 2019. Additionally, only a few private payer laws require the reimbursement amount for a telehealth-delivered service be equal to the amount that would have been reimbursed had the same service been delivered in person. Because so many states now have private payer reimbursement bills, the more common policy change in relation to private payers is to amend a law to expand its applicability to additional specialties or policy types. For example, Michigan expanded the applicability of its private payer law to dental coverage.

Utah, on the other hand, which just passed its first private payer bill, singles out telepsychiatry services. While Utah is not the only state to limit private payer telehealth reimbursement requirements to a specific specialty (see Arizona and Alaska), it is the first state to make a distinction between in-network and out-of-network providers in its law. Under the new law (effective January 1, 2019), a health benefit plan is required to cover mental health services for in-network physicians or out-of-network psychiatrists only if an in-network consultant is not made available within seven business days after the initial request.

 

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