CMS Faces a Call to Improve Telehealth Coverage for Rural Health Providers

Several organizations are making an extra effort to lobby for expanded telehealth coverage for rural healthcare providers beyond the pandemic.

While telehealth advocates have been lobbying the Centers for Medicare & Medicaid Services to make permanent a number of rules enacted during the pandemic to improve access and coverage, they’re putting emphasis on telemental health services delivered through federally qualified health centers (FQHCs), rural health centers (RHCs) and critical access hospitals (CAHs).

Those facilities have been especially hard hit during the COVID-19 crisis. They were limited in how they could use connected health prior to the pandemic and have been able to greatly expand those platforms during the crisis, but now face the prospect of losing those freedoms if CMS doesn’t address them in the proposed 2022 Physician Fee Schedule.

“We agree that telehealth payment should be addressed for Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs), and also believe outpatient behavioral therapy services offered by Critical Access Hospitals (CAHs) are a key component of a comprehensive rural behavioral health strategy,” reads a letter recently sent to CMS Administrator Chiquita Brooks-LaSure and signed by 20 organizations. “Without action to ensure these hospitals can bill tele-behavioral health as they do in-person services, access to CAH-provided outpatient will be lost for thousands of Americans in rural areas.”

There are roughly 1,370 FQHCs in the US, though that number sits closer to 14,200 when taking into account “look-alikes” and service sites that operate like FQHCs. RHCs number about 4,500, and there are roughly 1,350 CAHs scattered across the country. Each of the three healthcare sites operate under different federal guidelines, and their value in providing care to underserved populations and in underserved parts of the country is well-proven.

In many instances, these sites offer services that their target populations would not otherwise be able to access, often because they can’t afford those services. This is especially true for patients in need of mental or behavioral health services or dealing with substance abuse issues, as specialists are hard to find and even harder to visit in person in rural and remote regions - particularly during a pandemic.

And while rural healthcare providers have been seeing success in using virtual visits to connect patients to care resources, they also need the reimbursements to keep those programs up and running.

According to the letter to LaSure, roughly 20 percent of America’s rural residents are dealing with some sort of mental health issue, and suicide rates are 40 percent higher in those areas. Those numbers rise even higher in Medicare populations, which tend to be older.

“Even in the absence of COVID-19, the ability of CAHs to furnish outpatient behavioral therapy via telehealth has improved continuity of care by easing some of the often-challenging transportation requirements in rural settings, which can be exacerbated during the winter months,” the letter ststes. “CAHs serve communities characterized by access to care barriers, and CMS’ flexibilities have enabled CAHs to not only maintain access to outpatient behavioral therapy during the COVID-19 PHE, but it has also driven CAHs to identify and implement more efficient and clinically appropriate delivery of care models that leverage telecommunications technology.”

“Given the enormity of the challenge ahead of us, we must leverage our entire rural safety net to address these surging behavioral health needs,” it concludes. “We strongly believe that CMS should ensure CAHs, RHCs, FQHCs, and other providers are all equipped to fully leverage telehealth and that they are able to bill for clinically equivalent services the same way they would an in-person service.”

The letter is signed by, among others, the Alliance for Connected Care, American Psychiatric Association, National Association of Rural Health Clinics, National Rural Health Association and a handful of health systems.