California Eyes Post-COVID-19 Telehealth Policy for Medicaid Patients

California’s Department of Health Care Services is planning an aggressive post-COVID-19 telehealth policy for the state’s Medicaid program.

In a 14-page report issued this week, the DHCS has proposed to make permanent several telehealth measures enacted to address COVID-19, including payment parity, expanded coverage for services delivered by federally qualified health centers and rural health centers and some coverage for audio-only telehealth, such as phone calls.

In announcing its plans, the agency pointed out the huge increase in telehealth adoption during the public health emergency, brought on by a need to switch from in-person to virtual care and helped by state and federal measures easing access to and coverage of telehealth. It also pointed out that telehealth has helped to address significant barriers to access that had plagued underserved communities long before the pandemic.

“DHCS has heard from providers, Medi-Cal managed care plans, and professional associations that no show rates for appointments have significantly decreased as a result of the ability to provide health care services utilizing various telehealth modalities,” the agency reported. “This could be due to the flexible nature of the services being provided from the beneficiary’s home or community. Reduced no-show rates indicate that the existing telehealth flexibilities are helping Medi-Cal beneficiaries to access services in ways that work for their individual circumstances.”

“DHCS has also heard anecdotally that many beneficiaries prefer receiving health care services through various telehealth modalities because it reduces long travel distance on public transportation, prevents having to take time off work, reduces wait times to see a provider, and/or avoids parents having to arrange for child care,” the notice concluded. “All of those factors can be obstacles to in-person visits, reducing access to care.”

The proposals fall in line with policy and regulation discussions in many states, where lawmakers want to set the ground rules for telehealth coverage and access beyond the PHE, when the emergency measures end. Telehealth advocates are worried that healthcare providers will scale back or even end telehealth services if they don’t see those measures extended.

Specifically, by July 1, DCHS plans to enact the following recommendations:

• Allow specified FQHCs and RHCs to establish a new patient, located within its federal designated service area, through synchronous telehealth;
• Make permanent the removal of the site limitations on FQHCs and RHCs, including allowing them to provide telehealth services to the patient’s home;
• Expand synchronous and asynchronous (store-and-forward) telehealth services to 1915(c) waivers, the TCM Program and the LEA Medi-Cal Billing Option Program (LEA BOP);
• Add synchronous telehealth and telephonic/audio-only services to State Plan Drug Medi-Cal;
• Require payment parity between in-person visits and synchronous telehealth services, as long as they meet all of the associated requirements of the underlying billing codes, including for FQHC/RHCs;
• Expand the use of clinically appropriate telephonic/audio-only, other virtual communication and remote patient monitoring for established patients, subject to a separate fee schedule and not billable by FQHC/RHCs; and
• Provide that the TCM Program and the LEA BOP will follow traditional certified public expenditure (CPE) cost-based reimbursement methodology when rendering services via applicable telehealth modalities.

In its report, DCHS isn’t planning on continuing four telehealth provisions past the PHE. Those focus on audio-only telehealth services as a billable visit to an FQHC or RHC and reimbursed at the PPS rate, the use of that modality to establish a doctor-patient relationship with a new patient, and payment parity for those services. It’s also recommending discontinuing freedoms extended to Tribal 638 clinics, since the federal government sets long-term policy for those sites.

“Given the underlying intent of and level of care provided, DHCS does not believe it is appropriate to pay FQHC/RHC and/or non-clinic providers for less involved and less costly modalities, such as a telephonic/audio-only visits, e-consults, or e-visits, at the same rate as a visit conducted in-person or through synchronous telehealth modalities,” the agency said – adding that it would like to negotiate coverage for some of those services in an Alternative Payment Methodology.

The agency’s goals fall in line with those outlined by California Governor Gavin Newsom in his recent State of the State address and proposed 2021-22 budget – including coverage for RPM programs, a delivery method fast becoming popular with providers looking to move care from crowded hospitals into the patient’s home.

The document is yet another example of states taking the lead in looking to establish telehealth policy beyond the pandemic, something the federal government hasn’t yet done. Congress, specifically, has come under scrutiny for not making telehealth a priority, though in its defense it does have a busy agenda.