In 2021, the Alliance for Connected Care was instrumental in the formation of numerous group efforts to influence federal and state policymakers, advocated directly to Congress, and continued to build evidence and information needed to support permanent telehealth.
While the continuing public health emergency (PHE) delayed action by Congress on telehealth, we believe we are well positioned to ensure there is action before the end of the PHE. As more and more data comes out on telehealth, policymakers are coming to see the value of virtual care and coming to understand that this access generally does not lead to inappropriate or unnecessary health care utilization.
The Alliance has shaped thinking on Capitol Hill and convened stakeholders to advocate for the need to extend flexibilities around the telehealth safe harbor enacted in the CARES Act for individuals with high-deductible health plans coupled with a health savings account (HDHP-HSA) before the impending cliff on December 31, 2021. While this deadline has been missed, we came very close on this in 2021 and believe there is a good chance of success early in 2022.
Letter to Congress to Extend the HDHP-HSA Telehealth Flexibility – The Alliance convened a sign-on letter urging Congress to extend the CARES Act flexibility that enabled employers and insurers to offer pre-deductible coverage of telehealth services for individuals with HDHP-HSAs. This letter was signed by over 70 organizations, which included patient groups, clinician organizations, and employer coalitions. Building on this work, the Alliance advocated for bipartisan legislation in the House and Senate – the Telehealth Expansion Act and the Primary and Virtual Care Affordability Act.
The Alliance continues to push for Congress and CMS to make permanent the many telehealth flexibilities provided during the COVID-19 pandemic. The Alliance strongly advocates for Congress to advance permanent telehealth reform including, at a minimum, removing arbitrary restrictions on where a patient must be located in order to utilize telehealth services; ensuring federally qualified health centers, critical access hospitals, and rural health centers can furnish telehealth services; authorizing the Secretary to allow additional telehealth practitioners, services, and modalities; and removing restrictions on telemental health services.
430 Group Letter to Congress to Address ‘Telehealth Cliff’ – The Alliance for Connected Care was instrumental in the formation of a group letter to Congress signed by more than 430 national and regional organizations outlining the immediate actions necessary to ensure CMS has the authority to continue to make telehealth services available once the national COVID-19 public health emergency ends, and making clear that Medicare beneficiaries will lose access to virtual care options if Congress does not act, otherwise known as the ‘telehealth cliff.’
State Licensure Flexibilities
The Alliance has been active at the state-level on issues around cross-state licensure and the need to reform outdated licensure laws that impose barriers in access to care for patients. View our activity here, and information on our Medical Excellence Zone effort here.
Governor Letter on Maintaining Licensure Flexibilities – The Alliance co-led a letter signed by more than 230 organizations and sent to all 50 governors stressing the urgency of expiring licensure waivers and the impact on patient access to care. The letter urges state governors to act immediately to ensure patients can access the care they need where they reside and when they need it, and outlines a set of principles to consider for licensure policies that should be in place right now to ensure patient access to care.
DEA Special Telemedicine Registration
The Alliance has continued to advocate for the DEA to issue the long overdue Special Registration for Telemedicine Prescribing of Controlled Substances. View our activity here.
Letter to ONDCP Special Telemedicine Registration – Building on 2020 efforts convening over 80 organizations in a letter to the Drug Enforcement Administration (DEA) calling on the DEA to finalize the special registration for telemedicine, the Alliance continued to push this issue in 2021. A letter to the White House Office of National Drug Control Policy (ONDCP) applauded their inclusion of the telemedicine special registration for the prescribing of controlled substances this year as part of the Biden Administration’s First-Year Drug Policy Priorities. The anticipated registration would enable a practitioner to deliver, distribute, dispense, or prescribe via telemedicine a controlled substance to a patient who has not been medically examined in-person by the prescribing practitioner.
Federal Telehealth Data State of Play
After nearly two years of expanded telehealth access, the federal government is beginning to release data demonstrating telehealth’s impact on access to care, quality and outcomes.
The Alliance keeps a tracker of HHS Office of Inspector General (OIG) telehealth-related work plan items. Please see linked a list of pending and released OIG reports
2021 Report Highlights and Key Findings:
Patients are seeing their own providers – Most beneficiaries received telehealth services from providers with whom they had an established relationship. Notably, 84 percent of beneficiaries received telehealth services only from providers with whom they had an established relationship. As demonstrated, beneficiaries and the community do not need arbitrary guardrails like established relationships and in-person requirements to ensure beneficiaries are getting the care they deserve. Patients are maintaining their own providers when possible and appropriate. We believe this will continue but as telehealth models evolve, patients should have the choice to see other providers with whom they do not have a previous relationship.
Increased access and positive effects– Among states who evaluated their telehealth programs, both found positive effects, and among those basing their judgements on experience, more than half reported telehealth increased access.
Produced savings – In addition, one of the states that also analyzed its data on access found that, prior to the pandemic, telehealth produced savings of $8,600 in emergency room avoidance for one managed care plan, as well as $484,000 in reduced transportation costs for another managed care plan.
Recommending licensure reciprocity – OIG recommended states examine the use of licensure reciprocity and compacts – and specifically used the nursing compact as an example of a successful compact.
The report also found insightful trends on the kinds of services Medicare beneficiaries sought through telehealth. In 2020, telehealth visits comprised a third of total visits to behavioral health specialists, compared to 8 percent of visits to primary care providers and 3 percent of visits to other specialists.
In addition, the report identified trends in telehealth use by race/ethnicity. Overall, Black people had slightly lower telehealth use than White people, while Asian people and Hispanic people had higher use. However, while White beneficiaries had more telehealth visits overall, the percentage of beneficiaries who had at least one telehealth visit was higher among Black beneficiaries.
State Medicaid Telehealth Policies Before and During the COVID-19 Public Health Emergency – HHS ASPE also issued a report of state Medicaid telehealth policies before and during the COVID-19 public health emergency, finding utilization of telehealth increased more than 20-fold, from roughly 6 telehealth services per 1,000 Medicaid and Children’s Health Insurance Program (CHIP) beneficiaries in February 2020 to over 150 per 1,000 in April 2020. Rates have declined after April but still remained far above the pre-pandemic levels.
CMS Telehealth Data Snapshot
Medicare Telemedicine Data Snapshot Overview – CMS released a new data snapshot of Medicare fee-for-service and Medicare Advantage telehealth utilization from March 1, 2020 through February 28, 2021. Overall, more than 28 million beneficiaries used telemedicine – representing a more than 3,000 percent increase over the previous pre-pandemic period. In addition, 44 percent of rural beneficiaries and 55 percent of urban beneficiaries used telemedicine.
2021 Telehealth Summit for Health Systems
In April 2021, the Alliance hosted a Telehealth Summit for Health Systems with participation from over 300 attendees.
Major policymakers and stakeholders participated in the Summit including Senator Roger Wicker, Representative Mike Thompson, and White House Domestic Policy Council Deputy Director Christen Linke Young.
The event also featured breakout sessions led by health system executives from Ascension, Intermountain Healthcare, MedStar Health and Stanford Health Care, focused on consumer engagement in virtual care, post-pandemic licensure portability, hardwiring virtual care transformation and improving access across the digital and social divide.