For telehealth policy development, 2018 has been a major year. Activity on both the state and federal level have pushed for greater utilization and integration in using telehealth to provide health care services. For the first time since 2008, there were changes to federal law to expand the location of where telehealth could take place for Medicare enrollees. The Bipartisan Budget Act of 2018 expanded to include the home as an eligible originating site for end stage renal disease services and allowed acute stroke services to be provided in both rural and urban locations. The SUPPORT for Patient and Communities Act had similar changes. The SUPPORT Act removed the originating site geographic requirements and allowed the home to be an eligible originating site but only for individuals being treated for substance use disorders or a co-occurring mental health disorder. These were narrow exceptions and have been specifically tailored to address certain conditions, but are the first major federal statutory changes to the limited telehealth policy that has been seen in a decade.
However, not all impactful policy changes are made through law. The Center for Medicare and Medicaid Services (CMS) has been active over the years adjusting Medicare reimbursement policy through administrative action and 2018 was no different. Beginning January 1, 2019, CMS will now pay for what they term “Communication Technology-Based Services” which include a check-in between patient and physician that does not result in an office visit and can be through phone, live video or store-and-forward and provider-to-provider consultation where both providers could be reimbursed. As these services are labeled “Communication Technology-Based Services,” the statutory telehealth limitations do not apply, though they do face other requirements/limitations.
A major factor in the increased activity around telehealth policy changes in 2018 is due to the opioid epidemic facing the country. Policymakers are trying to find ways to get the services to address substance use disorder (SUD) to the locations that need them the most, in many cases, rural areas. Telehealth is being increasingly looked to as a potential solution and not only by federal, but state policymakers as well. In 2018, there was a trend in state legislation to find ways to utilize telehealth in treating SUD patients. SUD pilots, policies that would allow for mental and behavioral health counselors to be reimbursed, and changes to existing policies that limited where telehealth could take place had clear roots in the concern over this public health issue.
Looking forward to 2019, I believe what we can expect to see is continued interest in the utilization of telehealth to treat SUD. We also can look forward to more impactful policy changes for telehealth in general. In the last quarter of 2018, California’s Medicaid program, Medi-Cal, issued draft language to update its telehealth provider manual that included one of the most progressive telehealth policies seen: allowing the provider to decide whether it was appropriate to use telehealth (live video or store-and-forward) and paying for that service. The Medi-Cal draft language also had no limitation on specialty, and no specific list of CPT codes that would be reimbursed. If certain conditions were met (such as the definition of the CPT code requiring some in-person element), it would be reimbursed. This would be one large step towards normalizing telehealth and simply looking at it as another tool the provider can use to deliver services, much like a stethoscope. It has been a position CCHP has always held and talked about and we are pleased to see it finally being seriously considered.
CCHP itself has gone through major changes in 2018 which marked a full year since the passing of Mario Gutierrez, our previous Executive Director. While Mario’s presence has and will always be missed, CCHP has strived to build on the work he started and believed so much in. I want to take a moment to thank the incredible effort the CCHP staff have made that have contributed to the push in telehealth policy changes. Thank you to: Laura Stanworth, Program Administrator, for spearheading, simultaneously, CCHP’s website overhaul and redesign AND our office move; Christine Calouro, Policy Associate, who led the redesign of CCHP’s 50 State Telehealth Report and continues to provide exemplary technical assistance to people looking for telehealth policy questions; Trey Bierman, Project Coordinator, who provided invaluable assistance to Laura and Christine and published his first peer reviewed journal article; and Ray Dizon the Coordinator for the National Consortium of Telehealth Resource Centers for whom CCHP acts as the Administrator for his tireless efforts on behalf of the fourteen telehealth resource centers located throughout the country. It takes a team effort to be successful and each person has contributed greatly not only to CCHP’s success, but the continued expansion and utilization of telehealth.