How Should State Medicaid Programs Expand Telehealth Coverage?

With most state governments enacting emergency measures to improve Medicaid coverage for telehealth services during the coronavirus pandemic, a national law firm has drafted a list of actions those states could take to make those changes permanent.

Jacqueline Marks, a manager with the Manatt Health division of Manatt, Phelps & Philips, says states and connected health advocates have recognized the value in extending telehealth coverage – especially for children – during the COVID-19 crisis. Now they’re faced with trying to figure out which emergency measures were effective enough to keep in place.

To that end, she offers suggestions on policy changes for coverage and reimbursement for certain modalities, sites of care and services for children.

With regard to video visits, almost every state broadened the definition of a video visit during the pandemic. Marks no suggests a new policy that “covers all medically necessary and clinically appropriate services covered via video visit,” with reimbursement at the same rate that a provider would receive for in-person care.

Many states also expanded coverage during the pandemic for audio-only phone services, noting that underserved populations often don’t have easy access to audio-visual telemedicine platforms or broadband. The challenge going forward is that, outside of a public health emergency, this type of interaction isn’t appropriate for all healthcare services.

Marks suggests a two-pronged approach to this issue. First, create a policy that allows coverage for audio-only interactions in place of in-person or video visits for select services that can be properly handled by a telephone call. Second, develop telephonic evaluation and management codes that allow provider to receive some reimbursement for brief check-ins over the phone.

“Both types of audio-only visits will be important to maintain after the public health emergency ends, in order to ensure equal access to care for all patients, regardless of their location or income level,” she says.

With the pandemic curbing in-person care, many health systems looked to telehealth to enable care providers to connect with patients in other locations, such as the home. They also sought to use the platform to allow care providers to work from their own homes. This altered the dynamic of the telehealth interaction, which normally places either the provider or the patient – or both – in a recognized healthcare location.

As health systems look to shift more care out of the hospital, clinic or doctor’s office, Marks says state Medicaid programs should be receptive to changing the definition of both originating and distant sites for telehealth. They should make permanent policies that allow patients to be treated at home via telehealth, and that allow providers to deliver care from their homes.

Marks also sees opportunities for state Medicaid programs to expand coverage for a range of children’s services beyond the pandemic. She suggests encouraging in-person well-child visits for children up to 24 months of age, while adding telehealth as an option for children 24 months and older during a public health emergency and for up to two quarters after that emergency.

“This can ensure continued coverage of these important services for an age-appropriate population during future emergencies,” she says.

She also suggests making permanent a policy that covers and reimburses for the delivery of specialized therapy services via telehealth, and providing coverage for select early intervention services via telehealth “in a clinically appropriate manner.”

Finally, Marks suggests that state Medicaid programs expand coverage for behavioral health services delivered via telehealth, including services for children living with autism.

“COVID-19 has highlighted the critical role that telehealth can play in making behavioral health services more accessible for patients,” she says. “Going forward, it is likely that states will continue offering these services via telehealth modalities such as video and audio-only visits.”