SCTA Position on Telehealth Reimbursement Policies Post-COVID-19

Telehealth Policy and COVID-19 Recovery Position Statement

May 29, 2020

SCTA: The South Carolina Telehealth Alliance (SCTA) is a collaboration of health systems, primary and specialty care providers, state agencies, and other shared-mission support organizations that work together to improve the lives of all South Carolinians through telehealth. In recognition of this collaboration, the American Telemedicine Association awarded the SCTA its President’s Award for Transformation in Healthcare Delivery in 2019. The SCTA includes more than 450 connected care sites throughout the state and is administratively headquartered at the MUSC Center for Telehealth, one of only two Telehealth Centers of Excellence in the nation.

COVID-19: When faced with a highly contagious pandemic such as COVID-19, South Carolina is fortunate to have an extensive telehealth network already in place that can be deployed to provide efficient care without compromising public health. Telehealth has been an essential component of COVID-19 preparedness and response, allowing providers across the country to reach more patients while managing increasing demands on the healthcare workforce. Telehealth is being utilized to slow the spread of the virus; monitor and provide high-quality care to those infected with the disease; and protect vulnerable patients and access to other types of critical healthcare services.

South Carolina was the first state in the nation to stand up free virtual care screenings paired with remote specimen collection sites. To date, SCTA member health systems have conducted over 100,000 virtual COVID screenings across the state. SCTA members have also launched telehealth-based efforts to expand free COVID-19 testing services in target rural and at-risk communities. This has been the result of unprecedented collaboration among South Carolina’s hospital systems, primary care providers, rural health clinics, and local community leaders.

Telehealth has been instrumental in helping health systems and providers mitigate disruptions in care pathways and remain financially viable. Over the past several months, health systems have transitioned ambulatory, mental health, and other specialty services to telephonic and virtual care platforms. This has protected access to care for patients, while allowing patients who do not require hospitalization to stay home, alleviating overcrowding and cutting down on the risk of COVID-19 exposure for healthcare workers and vulnerable patients. Patient reported outcomes data have indicated high patient satisfaction and a desire to continue these services due to enhanced accessibility, flexibility, and privacy.

Policy: At the federal level, the Department of Health and Human Services (HHS) and Centers for Medicare and Medicaid Services (CMS) have enacted temporary policy changes that have facilitated these services by increasing flexibility and reimbursement for telehealth for the duration of the public health emergency (PHE) period. Within SC, the SC Department of Health and Human Services (SC DHHS) and private payers such as SC Blue Cross Blue Shield (SC BCBS) have followed suit.

Federal:

As we look toward the “recovery” phase of COVID-19, Congress and the Administration should extend the telehealth policy changes beyond the emergency declaration period. This includes the permanent removal of geographic, site, provider, and service type restrictions that have historically presented barriers to telehealth utilization. It also includes provisions allowing federally qualified health centers and rural health centers to serve as distant provider sites.

Congress and the Administration should implement policy that ensures virtual services are included across all health plans. Varying reimbursement rates and restrictions enforced by major payers represent a burden for patients and a barrier to delivering care in the safest possible settings. Inclusion across health plans allows for equitable access to all patients, can lower total health expenditures, improves convenience for patients, and improves presenteeism at places of employment.

State:

At the state level, SC DHHS should maintain its expanded telehealth coverage beyond the emergency period. This includes the permanent removal of restrictions that if reinstated, would prohibit Medicaid beneficiaries from receiving behavioral health, pediatric, and other types of specialty care via telehealth. It also includes both telephonic and video-based forms of telehealth.

Additionally, private payers—such as SC BCBS—should maintain reimbursement at levels equal to that of in-person care and not revert to reduced reimbursement levels. Reimbursing telehealth visits at rates considerably less than in-person care disincentivizes providers and health systems from utilizing telehealth.

Finally, the General Assembly should take legislative action to mandate telehealth coverage and payment parity. South Carolina is one of the last states in the country without a telehealth parity bill in place. Enacting strong parity legislation would build on the legislature’s long commitment to telehealth and ensure its sustainability into the future and beyond this crisis.

Federal, State, and Local:

Federal, state, and local governments should also consider policy that systematically addresses barriers preventing vulnerable populations from accessing telehealth services. Barriers include lack of internet connectivity for those in rural or low-income communities and costs associated with audio-visual devices and connected health monitoring equipment.

Conclusion: Long-term enactment of the changes recommended above will be critical to COVID-19 recovery, allowing patients and providers to continue to practice safe “social distancing” protocols in order to mitigate future waves of infection. It will protect access to high-value care for all patients, particularly those with transportation, occupational, or geographic challenges. It will also aid in economic recovery by allowing hospitals, community health centers, and other providers who have been negatively financially impacted by the COVID-19 crisis to receive reimbursement and thus maintain clinical service continuity with minimal financial loss. Telehealth has emerged as a crucial tool in flattening the curve on COVID-19 cases and meeting healthcare needs across South Carolina, especially in rural and underserved communities. These proposed policy changes will allow SC and other states to build upon, not stymie, the innovation that has resulted from the pandemic helping to transform the health care system toward more cost-efficient and convenient models of care.