Health Reform WK-EDGE CMS releases telehealth guidance for rural health care and SUPPORT patients
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Tuesday, April 14, 2020

CMS releases telehealth guidance for rural health care and SUPPORT patients

By Gregory Kane, J.D., M.B.A.

The CMCS provided an informational bulletin on the use of telehealth capabilities for rural health care and opioid prevention and recovery programs.

CMS released a Center for Medicaid & CHIP Services Informational Bulletin (CIB) identifying opportunities for the use of telehealth delivery methods to increase access to Medicaid services and to services under section 1009(b) of the Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment for Patients and Communities Act (SUPPORT Act). The telehealth delivery methods may also be applicable in responding to the COVID-19 public health emergency (CMCS Informational Bulletin, April 2, 2020).

Background. Telehealth is an umbrella term that encompasses the full range of services provided remotely via two-way, real time, interactive communications between the beneficiary and a clinician at different locations. This includes video-conferencing, store and forward, remote patient monitoring and mobile health. Telehealth could increase access to services in underserved areas by increasing the availability of providers within a state so as to mitigate barriers to treatment through expanded access to a limited workforce. The CIB addresses the use of telehealth services regarding rural health care and the SUPPORT Act. It also provides guidance on furnishing services and treatments for high-risk individuals, including American Indians and Alaska Natives, adults under the age of 40, individuals with a history of non-fatal overdose and others.

Rural Health Care. With approximately 60 million people residing in rural areas, those communities face unique barriers to accessing care including distance and transportation, limited access to services and workforce shortages. Telehealth can be a cost-effective service delivery method to furnish care and services to beneficiaries. Medicaid law and regulations do not specifically address telehealth delivery methods or criteria allowing states broad flexibility in designing the parameters of telehealth delivery methods so long as the underlying services are consistent with the overarching provisions in section 1905(a) of the Social Security Act and the state’s own plan and policy framework as a Medicaid benefit. Federal requirements for efficiency, economy and quality of care must be satisfied in order to receive federal financial participation for Medicaid covered services. States are allowed to set different rates for services provided through telehealth delivery methods. A State Plan Amendment (SPA) is not required to incorporate telehealth delivery methods if there are no changes to the 1905(a) benefit descriptions, limitations or payment methodologies. An SPA is required when states add specific distinctions for coverage or different reimbursement methodologies for services provided through telehealth delivery methods. When using managed care delivery systems, Medicaid managed care plans are not limited by payment arrangements outlined in the state plan and could pay alternate fees for additional provider types or for other telehealth uses so as to improve access and increase provider capacity.

SUPPORT Act. Section 1009(b)(1) of the SUPPORT Act requires guidance to states on federal reimbursement for services and treatment for substance abuse disorders (SUDs) under Medicaid delivered via telehealth. In general, 1905(a) Medicaid benefits are covered for assessment, medication-assisted treatment, counseling, and medication management and medication adherence with prescribed medication regimen. The Controlled Substances Act (CSA) permits the prescribing of controlled substances via telemedicine in certain circumstances, but it is a per se violation of the CSA to issue a prescription for a controlled substance without having conducted at least one in-person medical evaluation.

School-based health centers (SBHC) are not a recognized Medicaid facility benefit, but they may qualify if they meet the requirements of the clinic benefit or the Federally Qualified Health Center benefit. States may elect to cover SUD treatment services such as assessments, counseling, or medication management under several Medicaid benefits.

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