The American Hospital Association estimates that the country’s health care systems are losing an average of $50.7 billion per month. When analysts enthusiastically described telehealth as a money-saver over the last several decades, they were not referring to the financial impact on traditional payers and health systems. They also did not anticipate that these powerful institutions would initiate telehealth coverage rollbacks prior to the end of a Public Health Emergency (PHE) to offset their losses.
It is no wonder then, that providers began complaining to their state insurance commissioners after telehealth coverage rollbacks started prior to June 4, when Aetna, United Healthcare, and Anthem ended no-cost coverage of non-COVID telehealth for commercially insured members. The Florida Daily Post summarized the issue with these words: “Now, due to the financial strain on health care systems and insurers, the increase in telehealth use may be forced to shrink even though the public health crisis remains.”
Given the continuance of the Public Health Emergency until January 30, 2021, companies such as UnitedHealthcare (UHC) have again been in the news with yet more telehealth coverage rollback announcements. The STAT News reported that UBH has stopped waiving telehealth copays as of October 1 for some plans, while the UBH company website explains that such telehealth coverage rollbacks are only in effect for specified markets. The UBH website also states that in other cases, telehealth coverage is expanding, although details are not given. The Aetna website has announced a similar process, which is set to take effect on December 31, 2020.
The average clinician and/or consumer may have trouble keeping informed. Complications abound. Private insurance plans have historically differed not only from one another within a state, but also from each other across states. A Blue Cross in one state can operate quite differently from a Blue Cross in another state. Similarly, many state-funded Medicaid plans operate with different rules and dates for how they handle coverage. Most clinicians are well aware that such differences are nothing new. Now that telehealth coverage rollbacks are the topic of discussion, however, these pre-existing complications and contradictions are compounded from one state to another.
The STAT News aptly summarizes the problem this way:
However, patients who do learn of the costs before scheduling such a visit will likely face one of three scenarios, depending on costs… A patient may decide to go through with the virtual visit, with the patient either paying any outstanding costs him or herself, or the hospital or clinic shouldering all or part of that cost; a patient may opt for an in-person visit, or a patient may choose to skip the appointment altogether. There’s also the possibility—if the patient only learns after the fact that his or her visit wasn’t covered—that he or she may “get hit with a surprise bill,” STAT News reports.
What about Medicare and Medicaid?
Interestingly, the Centers for Medicare and Medicaid Services (CMS) has taken the exact opposite tack. Government payers seem to be working to retain current COVID-related waivers. CMS has issued repeated reports and statements about making its waivers permanent until COVID-19 is no longer a public health emergency. It has already proposed codifying many of them long-term, and more than a dozen laws are awaiting 2021 to be finalized. For details of recent CMS positions and a succinct summary of other laws scheduled to be given attention in January-February, see TBHI’s: October 2020 Telehealth Reimbursement News Update.
States Are Stepping In to Prevent Telehealth Coverage Rollbacks?
Several states have already passed laws to stop private insurers from telehealth coverage rollbacks, and more are on the way. In California, the Department of Managed Health Care, which regulates health plans covering many of the state’s insured residents, requires both commercial plans and Medi-Cal managed care plans to pay providers for telehealth at parity with regular appointments during the pandemic’s public health emergency (PHE). It also limits a patient’s out-of-pocket, “cost-sharing” to the traditional amount owed for an in-person healthcare visit.
Starting Jan. 1, a new California state law AB-744, will make that requirement permanent for all commercial plans in the state.
Six other states have pay-parity laws already in effect, according to the Center for Connected Health Policy. These states are Delaware, Georgia, Hawaii, Minnesota, and New Mexico. Washington state’s law will go into effect on Jan. 1, 2021, for a total of seven states to date. To learn more about your state’s plans to require telehealth payment past the PHE, visit your state’s insurance commissioner website, or contact the Center for Connected Health Policy.
Both health care systems and providers are searching for direction. Given TBHI’s vantage point, the following suggestions are offered:
Strategic Planning for Health Care Services
Health care services caught between traditional revenue models and innovation may want to consider a digital expansion with a telepsych service department. With telehealth consumer satisfaction reports at an all-time high, now is the optimal time to plant a foot into the digital space. Many groups are preparing for the new normal of hybrid telehealth, as detailed in Hybrid Telehealth: Telehealth and In-Person Healthcare. Increasingly being recognized as a viable combination of in-person and digital care, the hybrid approach is particularly appealing to groups who are reimbursed by CMS, given the multiple, recent statements about continuing payment for telehealth service after the pandemic. See CMS Announces Expanded Telehealth Coverage for Medicare, State Medicaid & CHIP Program and Telehealth Predictions: Access, Reimbursement & Fraud.
Telebehavioral health has not only been the most frequently reimbursed area of all telehealth and telemedicine reimbursed by CMS, but now is positioned for growth as unprecedented numbers of people are reporting increased depression, anxiety, substance use, marital problems, bereavement, and other behavioral issues due to COVID. See TBHI’s 2018 post detailing the CMS report to Congress about telehealth usage by healthcare area: CMS Congressional Report: 85.4% of all Telehealth Users Had Mental Health Diagnosis.
Now is the time for health care systems to consider developing or enhancing their telepsych services. TBHI’s consultation, training, and staffing services can expedite the process. For information, visit this page.
Strategic Planning for Providers
Now that consumers have experienced the power and convenience of telehealth, providers may work with their professional associations to exert continued pressure on payers to cover telehealth long term. If the pushback we are already witnessing from state legislators for telehealth coverage rollbacks is a predictor of the future, telehealth is here to stay, regardless of the financial strain on insurer’s wallets, but progress will be impeded. In the words of an 11/10/2020 announcement by HIMSS entitled, Billing Medicare and Private Payers for Telehealth Visits: What to Expect Post-Public Health Emergency:
It can be expected that post-PHE, payers will enact policies to limit the scope of telehealth coverage. Many patients appreciate the convenience of telehealth and it is likely the number of telehealth visits will continue to increase post-PHE. As patients use telehealth to interact with their physicians more often, payers will be expected to reimburse more visits, negatively impacting their financial performance.
Here’s a short list of other actions to consider:
- Understanding telehealth billing basics and following telemedicine billing and coding guidelines have never been more important. TBHI recommends that providers contact payer websites to review policy announcements, and if asking questions, get information in writing.
- If uncertain about appropriate telehealth billing and reimbursement coding or other practices, register for TBHI’s Maximizing Reimbursement Strategies in Telehealth to get your questions answered.
- Write to your legislators to encourage them to take an active role in telehealth expansion legislation. Your voice counts. Exercise it by being the pebble in the shoe of your legislators, reminding them of your wish for them to vote for the many bills that will soon be heard in legislative offices across the land.
- Join your professional association(s) to help them advocate on behalf of your profession. Voices are louder when spoken through organized associations with strong legislative action agendas.
Current Telebehavioral Health Trends?
Most recently, TBHI has been consulting with health systems seeking to develop new revenue streams through telebehavioral interventions. Telebehavioral interventions are the least vulnerable to telehealth reimbursement rollbacks long term when compared to traditional in-office medical specialties such as oncology, pulmonology, cardiology, etc. In addition to historically high user satisfaction rates, telebehavioral health makes it easy for professionals to consider permanently expanding their practices with telehealth because it:
- Allows the user to avoid the often embarrassing stigma of going to a mental health or drug treatment facility,
- Affords the privacy and comfort of being helped in one’s own home for weekly sessions that can take a toll on one’s work hours when employed,
- Provides safety during the pandemic as well as other illness-prone times of the year such as flu season,
- Offers the ability for a well-trained teletherapist to establish rapport and a therapeutic relationship through video and other specialized technologies.
Many of TBHI’s more recent consulting clients are shifting their payer mix to government payers, and planning to gradually shift away from full caseloads of clients or patients from third-party, private carriers.
TBHI Professional Training and Consultation Options
TBHI specializes in teaching you how to relax when delivering telehealth. It offers you a step-by-step learning path of online training and consultation that helps you be legally and ethically compliant, clinically proficient, and able to handle even the most difficult of clinical scenarios. All training is evidence-based, available 24/7 through any device, and most count toward legal and ethical requirements for licensure. Consultation is available with and without staff training for enterprise clients.
- Telehealth Group Therapy — Exciting, highly interactive telehealth learning experience designed to get answers to your questions about legally and ethically managing telehealth group therapy. Digital class will allow you to connect with colleagues ahead of time to ask questions and share answers. Distinguished faculty will lead you through telehealth group therapy theory and exercises.
- Telehealth Clinical Best Practices Workshop — Live, interactive webinar, w/ 4 CME, or CE hours to discuss preventing and handling complex clinical issues.
- Evidence-Based & Practical Telesupervision Digital Workshop – Live, highly interactive telehealth workshop designed by telehealth supervisors for telehealth supervisors. Come interact, learn by doing, and experience how good it can be!
- Telehealth Training Catalog
- Micro Certifications to give you a broader range of legal and ethical grounding, and allow you to distinguish yourself as a TBHI-credentialed professional on your websites, in social media, directories, and other areas.