A Snapshot of Telehealth Payment Policies Across States

November 22, 2021 - Telehealth policies vary from state to state but in the past few months there have been some common regulation changes across the country. Specifically, states modified their Medicaid reimbursement policies for telehealth services, the Center for Connected Health Policy’s (CCHP) State Telehealth Laws and Reimbursement Policies Fall 2021 report revealed.

CCHP gathered data from state law, state administrative codes, and Medicaid provider manuals between June and September to identify the policy changes for each state.

Several changes extended or made permanent telehealth policies that were enacted in response to the COVID-19 pandemic.

Every state and Washington D.C. offers Medicaid reimbursement for some form of telehealth, but policies vary depending on the modality.

Live video is the most commonly reimbursed telehealth method, according to the report. However, some states may choose to only reimburse services with certain CPT codes while others reimburse all appropriate services that are covered under Medicaid.

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Reimbursement remains inconsistent across the country because states can decide to reimburse only specific providers and originating sites. But several states have adjusted their Medicaid policies in the last few months.

For example, Iowa changed its Medicaid policy to allow intern psychologists to offer telehealth services, Minnesota added Individualized Education Program services to its reimbursable services, and Utah is now covering telehealth services for mental health and substance use disorder.

The most common specialty provider additions to the telehealth arena in the last few months were physical therapists, occupational therapists, and speech-language pathologists, the report noted.

In contrast to live video telehealth, only 22 states recognize and reimburse for store-and-forward, or asynchronous, telehealth services.

“In many states, the definition of telemedicine and/or telehealth stipulates that the delivery of services must occur in ‘real time,’ automatically excluding store-and-forward as a part of telemedicine and/or telehealth altogether in those states,” the report stated.

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Some states make exceptions in order to cover certain asynchronous services. Maryland, which does not reimburse for asynchronous telehealth, does not consider dermatology, ophthalmology, and radiology as store-and-forward services and this allows them to reimburse providers for this care.

A few states say they have laws that require Medicaid to reimburse for store-and-forward telehealth, but CCHP did not find any evidence of reimbursement. Meanwhile, some states, including Hawaii, have allowed asynchronous reimbursement for only certain CPT codes.

Remote patient monitoring (RPM), another common telehealth modality, is reimbursable in 29 states. In the past few months, California, Michigan, and Washington state have added reimbursement for RPM to their Medicaid policies. However, many states have limits to these policies and may only offer reimbursement to home health agencies. Other common restrictions include limiting the type of monitoring device that can be used, the information that providers can collect, and the patient symptoms they can monitor.

Further, telehealth has highlighted care disparities in some populations, as it requires access to technology and internet. Audio-only telehealth proved to be a more equitable and accessible option for some.

Since spring 2021, nine states have made audio-only reimbursement permanent under Medicaid, bringing the total number of states to 22. Oregon passed a law that requires Medicaid to reimburse audio-only services—and all other telehealth services—at the same rate as in-person care. Some states like Kentucky will reimburse audio-only telehealth but encourage providers to use it only when there is no other viable option.

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States have recently altered their policies to loosen geographic and facility originating site restrictions as well. For example, Arkansas newly stated that patients can access telehealth services from their homes and Mississippi labeled federally qualified health centers and rural health clinics as acceptable distant site providers.

Additionally, nearly 30 states and D.C. allow schools to be considered an originating site, permitting students to receive mental health, speech, occupational, and physical therapy via telehealth while at school.

Since June, several states have made changes to professional requirements for providing care via telehealth including consent, licensure policies, and online prescribing.

Two states added consent requirements to their Medicaid policies, while Kansas, Arizona, Utah, and West Virginia added telehealth licenses or new licensing exceptions that make it easier for providers to offer telehealth services out of state. Several states participate in interstate compacts to facilitate out-of-state telehealth.

When it comes to prescribing medication via telehealth, states have different restrictions. Virginia implemented a policy that requires stricter regulation of virtual prescriptions for controlled substances. Meanwhile, Maine has prohibited private payers from restricting certain providers from prescribing medication via telehealth.

Outside of Medicaid, a handful of states have adjusted private payer telehealth policies. For example, Oregon made their telehealth reimbursement policy applicable to dental-only plans and Kentucky now requires equal coverage and reimbursement for telehealth and in-person care.