November 23, 2020 – The Alliance of Community Health Plans (ACHP) urged Congress to take steps toward making telehealth flexibilities permanent and to ensure that coronavirus testing is available to consumers without cost-sharing.
“One of the most important changes in health care delivery during the pandemic has been the unprecedented increase in availability and utilization of telehealth,” ACHP stated. “As telehealth has expanded access to care, testing for COVID-19 has been equally important in determining treatment paths.”
In order to move forward on telehealth flexibilities, ACHP offered four potential action items.
First, Congress could completely strip away the geographic restrictions that still govern telehealth.
This is certainly not a new recommendation. Other organizations have also been pushing for Congress to remedy or remove Section 1834m of the Social Security Act, which is responsible for imposing geographic restrictions on telehealth.
In 2019, telehealth organizations urged a Congress Telehealth Caucus to pursue the same route that it took in expanding coverage for home dialysis of end-stage renal disease and substance abuse treatment. An originating site, they argued, should include both rural and urban locations. At the time, it only encompassed rural settings.
In February 2020, before the coronavirus pandemic struck the US with full force, CMS loosened telehealth restrictions for shared-risk accountable care organizations, allowing home telehealth services to count toward spending targets.
Nonetheless, Section 1834m of the Social Security Act remained in place. ACHP characterized the law as “obsolete” and restrictive of patient access.
Second, Congress could expand flexibilities given to Medicare and accountable care organizations through December 31, 2022.
“Under current flexibilities, plans have been able to count telehealth as a covered benefit allowing them to deliver additional supplemental benefits to enrollees,” ACHP stated.
“Under law, MA bids for the next plan year are submitted the first Monday in June. Without certainty that telehealth will be covered during the plan year, plans will be forced to eliminate some benefits their enrollees currently enjoy to continue covering telehealth.”
By extending these flexibilities, CMS would have more time to gather telehealth data and direct Congress. Experts have indicated that collecting and analyzing more data on telehealth utilization and cost benefits will be crucial to settling tensions around telehealth reimbursement.
Third, Congress could endow HHS with more authority so that it can loosen the restrictions around which providers can offer telehealth. Again, ACHP stressed the opportunity for further telehealth data collection as a part of this strategy, in this case supporting Congressional decision-making around best uses for telehealth, remote monitoring, and other technologies.
Lastly, in order to increase flexibility around telehealth, Congress should establish a clear plan leading toward value-based reimbursement in Medicare telehealth. ACHP argued that concerns around the misuse of telehealth are misdirected. Congress could protect patients from improper use of telehealth by reforming incentives through discarding the fee-for-service model.
Apart from loosening telehealth restrictions, the payer organization emphasized new strategies around coronavirus testing.
ACHP recommended that Congress implement a national testing and contact tracing strategy to control the coronavirus pandemic.
Congress could also raise more funding for testing and distinguish between the public and private sector burdens for testing. Namely, ACHP argued that payers should not shoulder the responsibility for lab testing costs.
“Public health surveillance and other purposes for lab testing beyond tests required for managing a patient’s disease should not fall on private payers and the consumers they serve,” ACHP stated. “The government should be responsible for testing conducted for public health.”
Payers may be especially concerned about taking on the financial responsibility for coronavirus testing after a recent AHIP survey revealed the out-of-network costs associated with this endeavor.
The survey illuminated that more patients are going to out-of-network providers to receive their coronavirus testing and that these tests can cost over three times the original price of a coronavirus test.
AHIP likewise advocated for more federal funding to go toward covering coronavirus tests and also that Congress establish a benchmark for out-of-network testing costs.