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The Public Health Emergency (PHE), originally declared in March 2020, was renewed every 90 days through 2021, continuing the temporary telehealth coverage flexibilities from the Center for Medicare and Medicaid Services (CMS) South Carolina Medicaid, and private payers. This expanded coverage and reimbursement have made telehealth an important piece of the care continuum, as providers and patients who previously may not have considered a telehealth visit have now acclimated to using technology to provide and receive healthcare. Not only are South Carolinians using telehealth more regularly, but telehealth visits have become a necessary component to delivering high-quality care. Although the PHE continues into 2022, SC providers and payers agree that going back to pre-pandemic telehealth coverage policies is not an option. To assist SC Medicaid and other state- level payers in evaluating long-term coverage plans, the SCTA produced a document with recommendations and supporting evidence for sustained telehealth reimbursement and coverage after the eventual expiration of the PHE declaration.

Recommendations included

  • Permanently remove originating site restrictions

  • Cover all CMS approved mental health and registered dietician provider types as well as rehabilitation therapists

  • Permanently allow federally qualified health centers (FQHCs) and rural health centers (RHCs) serve as distant sites for telehealth

  • Continue coverage of virtual check-ins and audio-only telehealth services

  • Cover chronic care remote patient monitoring codes currently covered by Medicare

  • Cover interprofessional internet consultation (e-Consult) codes covered by Medicare

  • Cover behavioral health integration codes (including CoCM) covered by Medicare

The SCTA’s recommendations directly informed SC Medicaid’s FY21-22 Proviso Telehealth Report, which echoed many of the SCTA’s highest priorities, and outlined areas of alignment between the SCTA recommendations and Medicaid Managed Care Organizations (MCOs). Looking forward, we expect strong collaboration among providers, payers, and policy makers to work toward a more sustainable, permanent telehealth reimbursement landscape in our state.

SCTA Payer Priority Document (PDF)