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Telehealth

Telehealth is the use of telecommunications and information technology to provide access to health assessment, diagnosis, intervention, consultation, supervision and information across distance. At one time, telehealth in Medicaid had been referred to as telemedicine.

Telehealth seeks to improve a patient's health by permitting two-way, real-time interactive communication between the patient and the physician or practitioner at the distant site. This  communication often requires  the use of interactive telecommunications equipment that can include both audio and video components, but can also be conducted via audio-only, as states deem appropriate.

Telehealth includes such technologies as telephones, electronic mail systems, and remote patient monitoring devices, which are used to collect and transmit patient data for monitoring and interpretation.

State Telehealth Flexibilities

For most Medicaid benefits, federal Medicaid law and regulations do not specifically address telehealth delivery methods or the criteria for implementation of telehealth.  As a result, states have broad flexibility in designing the parameters of telehealth delivery methods to furnish services. However, underlying services must continue to meet the requirements of the overarching provisions in Title XIX of the Social Security Act (the Act), regulations, the federal policy framework of the covered Medicaid benefit, and the parameters of the state’s CMS-approved Medicaid state plan or a subsequent state plan amendment (SPA). Where Medicaid law or regulations set forth telehealth delivery requirements for specific benefits, those requirements must be observed. For example, the Community First Choice (CFC) Option at 1915(k) has general requirements for using telehealth for performing the assessment of need (§441.535), but does not have requirements for other CFC activities that could be performed using telehealth.

CMS Approach to Reviewing Telehealth SPAs

Unless required by regulation or policy, states are not required to submit a (separate) SPA for coverage or reimbursement of Medicaid coverable services delivered though telehealth if they decide to reimburse for services delivered though telehealth in the same way/amount that they pay for face-to-face services.

States must submit a (separate) reimbursement (attachment 4.19B) SPA if they want to provide reimbursement for services or components of services delivered through telehealth differently than is currently being reimbursed for face-to-face services.

States may submit a coverage SPA to better describe the services they choose to cover through telehealth, such as which providers/practitioners are identified by the state to use telehealth to deliver services; where it is provided; how it is provided, etc. In this case, and in order to avoid unnecessary SPA submissions, it is recommended that a brief description of the framework of telehealth may be placed in an introductory section of the state plan, e.g., Section 3 – Services: General Provisions 3.1 Amount, Duration and Scope of Services, and then a reference made to coverage through telehealth in the applicable benefit sections of the state plan. For example, in the physician section it might say that dermatology services can be delivered via telehealth provided all state requirements related to telehealth as described in the state plan are otherwise met.