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Common Wealth Fund Analyzes State COVID-19 Telehealth Changes

Center for Connected Health Policy

July 2021

Recommending Longer Term Expansion Data to Determine Permanent Policies

The Commonwealth Fund recently released an issue brief titled, States’ Actions to Expand Telemedicine Access During COVID-19 and Future Policy Considerations, to help inform future policy considerations for telehealth post-pandemic. Focusing on private insurance coverage, the authors reviewed pre-pandemic state telehealth statutes as well as state emergency actions related to telehealth between March 2020 and March 2021. The study found that 22 states made telehealth policy changes, mostly in regard to audio-only coverage, cost-sharing requirements, and reimbursement parity. Audio-only coverage and reimbursement parity were the most popular changes made to ensure expanded access to telehealth.

Notable pre-pandemic findings include:
-35 states required private insurance telehealth coverage
-25 states required insurers to limit cost-sharing
-15 states required private payer reimbursement parity
-3 states explicitly required audio-only coverage

Notable policy expansions during the pandemic included:
-5 additional states required telehealth coverage
-4 new states eliminated cost-sharing for services via telehealth
-10 states added a requirement for private payer reimbursement parity
-18 states moved to require audio-only coverage

The report also looked at methods of emergency telehealth expansion by states, finding that policy changes came in a combination of legislation, executive orders, and other agency actions such as bulletins and notices. The study found 8 states passed legislation, but that the primary method was administrative action, given its ability to be made quickly. Administrative changes also appeared to often hinge on existing statutory authority or executive orders creating such authority.

As part of the study’s methodology, the authors additionally interviewed insurance regulators in 10 states that had made telehealth expansions. Regulators highlighted the importance of audio-only coverage, both for older patients and their ease of use, as well as patients with behavioral health conditions that find it more comfortable. While some regulators expressed concerns related to increased costs with audio-only coverage, others highlighted billing parameters and how insurers have the ability to determine which audio-only visits qualify for reimbursement. The regulators also noted that almost all insurers were supportive of the temporary expansions, but that they’d likely oppose long-term payment parity requirements, even though one regulator commented how the work may be the same for a visit via telehealth as in-person. Interviews also revealed an insurer desire to pay lower rates for their third-party corporate telehealth providers, which regulators said may be less costly but also may fragment care, which can result in lower quality care and higher health care costs.

The report also covers existing research around the benefits of telehealth and suggests the need to address insurance and audio-only coverage long-term to reduce access issues and stabilize the coverage landscape for providers to continue investing in telehealth use. The study concludes with the recommendation that maintaining telehealth expansions may benefit payers and consumers if telehealth can be shown to reduce health care costs. This will require access to longer-term information to monitor its use, including stakeholder workgroups and formal data collection mechanisms. Of course, longer-term data requires longer-term expansions, which could trend states toward temporary extensions in the short-term, such as those recently enacted in Connecticut and proposed in California. As policymakers continue the call for telehealth data, the primary response from researchers seems to be the same call. In addition to telehealth expansion impacts on health care costs, the issue of improved access to care must remain a primary focus of data collection and evaluation as well to truly result in equitable policy adoption.

For more information on the actions states took to expand telehealth during COVID-19, read the Commonwealth Fund’s issue brief in its entirety - CCHP’s Policy Finder tool can also be used to look up COVID telehealth policy documents by state. New Mexico policy finder -

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