Last week the Department of Health and Human Services Office of Inspector General (HHS-OIG) released two new telehealth reports, both related to the use of telehealth to deliver behavioral health services to Medicaid beneficiaries. HHS-OIG breaks up their study into two reports:

*States Reported Multiple Challenges with Using Telehealth to Provide Behavioral Health Services to Medicaid Enrollees (Challenges Report) which focuses on state care delivery issues, and
*Opportunities Exist to Strengthen Evaluation and Oversight of Telehealth for Behavioral Health in Medicaid (Evaluation Report), which looks closer at state data collection and evaluation efforts.

The reports are both based on surveys HHS-OIG conducted with Medicaid directors from 37 states as well as various stakeholders in early 2020. The surveys were particularly focused around telemental health delivery through managed care organizations, however most stakeholders focused on general telehealth issues in their responses. While the information was gathered pre-pandemic, HHS-OIG applies the findings to support understanding and recommendations to the Centers for Medicare and Medicaid Services (CMS) around post-pandemic telehealth policy.

Key Challenges: Lack of Telehealth Training and Limited Broadband
In terms of challenges related to care delivery via telehealth, the number one issue reported by 32 out of 37 surveyed states, was a lack of provider and enrollee training. In HHS-OIG’s interviews, stakeholders described not only provider issues related to use of telehealth technology, but also lack of education around telehealth coverage and reimbursement policies. Lack of internet access came in as the second highest challenge, reported by 31 out of 37 states. Broadband issues raised included not only enrollees having insufficient broadband speeds, but some clinics in rural areas having no broadband access at all.

Other challenges provided by state Medicaid programs included:
-Concerns around how providers protect patient privacy and personal information.
-Lack of interoperability between provider electronic health record systems and how to increase provider sharing of patient information.
-The high costs of telehealth infrastructure, such as initial equipment costs as well as maintenance and repair costs.
-A lack of licensure reciprocity across states.
-A lack of understanding around telehealth consent policies.

Citing how CMS has given states broad flexibility in how they structure their telehealth policies, the recommendations from the report to CMS focus on increasing creation and dissemination of additional informational and educational resources, such as best practices amongst states, funding options related to broadband and interoperability, and creating a state plan amendment template that could additionally assist states in covering some ancillary infrastructure costs.

Evaluation: Telehealth Data and Oversight
Within the Evaluation Report which focused more on data collection and analysis, HHS-OIG found that only 3 out of 37 states are unable to track which services are provided via telehealth, however only 2 out of 37 states have evaluated that data specific to impacts on access to behavioral health services and only one state has evaluated telehealth impacts on cost. The report notes that though other states didn’t directly evaluate telehealth data however, they did provide information on observational telehealth impacts based on their experiences with telehealth. For instance, 17 out of 37 states reported that telehealth increases access to providers and a few states also noted potential cost savings, while 6 out of 37 said the impact of telehealth on cost is largely uncertain.

The final focus of the Evaluation report was related to telehealth quality assessments and oversight by Medicaid agencies. While 10 out of 37 states noted concerns around quality, one state mentioned quality as more of a clinical practice issue, and two states believed provider training could address such concerns. In regard to oversight, only 11 states were said to conduct monitoring specific to telehealth, while other states noted they oversee all services the same. HHS-OIG made much stronger and more specific recommendations when it comes to state oversight and evaluation, suggesting the need for additional telehealth specific measures by CMS, states, and managed care organizations.

Looking Ahead
The HHS-OIG reports highlight many of the broad issues and questions related to telehealth that have become forefront in policymakers’ minds over the past year and half, such as challenges around addressing the digital divide and how to best evaluate telehealth impacts. The recommendations point toward a few different potential post-pandemic pathways for CMS mainly around increasing education and oversight. As we’ve seen confusion grow around what state Medicaid agencies believe CMS allows them to do as permanent telehealth policy, such as around federally qualified health centers (FQHCs), perhaps the most essential recommendation made by HHS-OIG comes back to increasing coordination amongst state Medicaid agencies with CMS.

The reports’ limited scope to behavioral health services through managed care organizations is also notable in terms of policy application even though state and stakeholder responses may have been more general. For instance, many states and policymakers seem to be focused around Medicaid fee-for-service policies more so than managed care, as well as reimbursement challenges, such as payment parity and similar fee schedule considerations. In addition, the HHS-OIG study did not break down any differences or feedback by telehealth modality, while many states and stakeholders have been focused on the future of audio-only availability – especially as a way to address the challenge of limited broadband access.

In terms of evaluating data, while many states may have not had a data evaluation plan in place at the time of HHS-OIG survey, many now do as a result of recently enacted legislation predicated on the surge of use and attention to telehealth during the pandemic. Therefore, it may be interesting for HHS-OIG to consider conducting a similar more broad survey in a year or two after states have had more time to collect and wrap their heads around the data.

Challenges Report: https://oig.hhs.gov/oei/reports/OEI-02-19-00400.pdf

Evaluation Report: https://oig.hhs.gov/oei/reports/OEI-02-19-00401.pdf