The Center for Connected Health Policy (CCHP) has a Telehealth Policy Finder where you can look up all telehealth-related policies and regulations, including those related to Private Payer and Medicaid Reimbursement across all 50 states and the District of Columbia, as well as at the  federal level.

CCHP has also put together the following resources to help you compare and contrast the laws and reimbursement policies for each state, including those related to Private Payer and Medicaid Reimbursement.

 

Private Payer Reimbursement.  Most of the states in the MATRC region have some form of private (commercial) payer parity laws related to telehealth.  There are two types of parity laws. One is referred to as coverage or ‘service parity’.  Service parity means that commercial health plans may not deny reimbursement for a covered service solely because it was provided via telehealth.  This type of parity does not guarantee the same rate of payment.  The other type of parity is ‘payment parity’.  This requires commercial health plans to reimburse for telehealth services at the same rate as in-person care. These laws generally do not apply to self-insured plans.

 

Medicaid Reimbursement.  States have broad discretion in designing their approaches to telehealth since telehealth is a delivery method, not a benefit type. Telehealth is viewed as an alternative to the more traditional face-to-face way of providing medical care (e.g., face-to-face consultations or examinations between provider and patient). As such, states have the option/flexibility to determine whether (or not) to cover telehealth; what types of telehealth to cover; where in the state it can be covered; how it is provided/covered; what types of telehealth practitioners/providers may be covered/reimbursed, as long as such practitioners/providers are "recognized" and qualified according to Medicaid statute/regulation; and how much to reimburse for services delivered using telehealth, as long as such payments do not exceed Federal Upper Limits.

  • All fifty states and the District of Columbia have some form of Medicaid reimbursement for telehealth. No two state Medicaid policies are identical in their requirements and restrictions!  CCHP has created this video discussing how Medicaid telehealth policy works:

 

  • For more information about the specific Medicaid Policies found in one or more of the MATRC states, visit Telehealth In My State and then select your state of interest where you will find a section on Medicaid.

Frequently Asked Questions About Medaid and Telehealth:  

  • Is it true that for outpatient mental health clinics, Medicaid requires either the patient or the provider to be physically onsite at the clinic?

Technically yes. The first “Four Walls Rule” reference was CMS’ FAQ issued as a result of the 2/26/16 CMS State Health Official letter SHO #16-002 that announced changes to Medicaid payment policy for tribal entities.  Pre-PHE, this was never really thought of problematic.  Post PHE:

Some State Medicaid agencies have raised the Four Walls Rule as a concern and some may not even be aware that it exists.  There has been little coversation about it.  Nonetheless, technically this is a rule that CMS is just now addressing through this proposed rule.  The proposed rule would provide exceptions to the Medicaid clinic services benefit four walls requirement for Indian Health Service and Tribal clinics, and, at state option, for behavioral health clinics and clinics located in rural areas.

  • Can a Provider be located out of the country (either temporarily or permanently living abroad) and bill Medicaid for telehealth visits?

The short answer is No. Based on this CMS Guidance Letter to State Medicaid Directors,  Section 6505 of the Affordable Care Act amends section 1902(a) of the Social Security Act (the Act), and requires that a State shall not provide any payments for items or services provided under the State plan or under a waiver to any financial institution or entity located outside of the United States (U.S.).