A couple of weeks ago, CMS announced four new interventions, including Telehealth Networks, that will be tested as part of a Value-Based Insurance Design (VBID) model for Medicare Advantage (MA) plans starting in CY 2020.
The Telehealth Networks intervention allows MA organizations to test using access to telehealth services to meet certain provider network requirements, “as long as an in-person option remains,” according to CMS’s fact sheet.
This new telehealth intervention is consistent with a recently proposed rule for Medicaid managed care that would allow health plans to consider telehealth as a component of network adequacy in states that allow it. Under the VBID model, telehealth would be used to “augment and complement an MA plan’s current network of providers” and “appropriately allow MA plans to expand their service area to currently underserved counties” as noted in the fact sheet.
CMS will have the ultimate say regarding which MA plans may use telehealth to meet network adequacy requirements. One safeguard for consumers is that MA plans offering telehealth as part of the VBID model must ask enrollees if they prefer to receive services in person. Those that prefer traditional, in-person visits must still have access to these services.
The following two approaches will be tested under this telehealth proposal:
As part of using telehealth to supplement their current provider network, MAOs may have up to a third of the required in-network specialty providers provide care via telehealth. There are currently 27 specialty provider types used to determine network adequacy in MA and this evaluation is done at the county level. To be in compliance, “at least 90 percent of enrollees within a county [must be able to] access care within specific travel and distance maximums” according to the most recent MA Network Adequacy Criteria Guidance.
Ultimately, expanding the use of telehealth is expected to allow MAOs to serve more enrollees, especially in locations where MA plans were previously not offered. It’s unclear when CMS will release the full data from this intervention, but I expect them to have preliminary results by early 2020. If this proposal proves to be a success, the inclusion of telehealth as part of network adequacy will only increase and further advance the need to consider the need for quality oversight of telehealth services.