The Center for Medicare Advocacy’s mission is to advance access to affordable, quality health care for older people and people with disabilities. We recognize that the expansion of Medicare-covered telehealth services has helped many beneficiaries and their families, while helping to reduce transmission of the COVID-19 virus. Nonetheless, we urge policy-makers to study the current experience with telehealth, rather than making permanent a system developed during a crisis.
Legislative mandates and administrative authority have allowed the Centers for Medicare & Medicaid Services (CMS) to issue temporary waivers of Medicare rules. Combined, these waivers allow beneficiaries to receive a wider range of health services, from a broader array of providers, using more types of technology, including from home.
Although the country is still in the midst of the COVID crisis, some stakeholders are already pushing to permanently extend many of these changes. Concurrently, CMS has signaled it intends to make many of the changes permanent, and there is growing support in Congress for expanding telehealth. However, without study and publicly released data concerning the types of services provided, program spending, health outcomes, and quality measurements, decisions to make such expansion permanent are premature. Further, these decisions could fundamentally change care delivery for Medicare patients.
When assessing whether and how to expand Medicare coverage for telehealth, we suggest the following principles to help guide policymakers:
- Ensure any covered telehealth services are clinically appropriate;
- Ensure that telehealth options supplement, rather than replace, in-person care – and ensure that payment incentives align with this goal;
- Ensure that further expansion of telehealth does not exacerbate health disparities – and ensure that necessary actions and expenditures are authorized to address the digital divide faced by many Medicare beneficiaries;
- Require that any applicable beneficiary cost-sharing is disclosed up-front by providers;
- Ensure that any expansion of telehealth protects patient privacy and data security for personal health information; HIPAA privacy protections must apply to telehealth interactions between the patient and provider and personal health data must also be kept secure;
- Ensure any expansion of telehealth is identical in traditional Medicare and private Medicare Advantage, and that the services and necessary equipment to access telehealth are equally available to all beneficiaries – whether they are in traditional Medicare or Medicare Advantage;
- Ensure that telehealth does not (further) weaken Medicare Advantage network adequacy standards by allowing telehealth providers to count towards network adequacy;
- Require public release of data concerning Medicare-covered telehealth, including the type of services provided, programmatic spending, health outcomes, and quality measurements.
July 16, 2020 – D. Lipschutz, J. Stein