WHA Comments on Preliminary Draft Update to Medicaid Telemedicine Policy

March 31, 2017

WHA praised the Department of Health Service’s (DHS’s) Medicaid Telehealth Policy Team for their recommendation to include telemedicine services provided in emergency department and dental settings in the Team’s draft updates to Forward Health Topic #510 addressing telehealth reimbursement under the Wisconsin Medicaid program. WHA’s comments were submitted March 30 and were in response to a request for comments by WHA from the Medicaid Telehealth Policy Team.

"We appreciate the inclusion of emergency departments as originating sites," wrote WHA General Counsel Matthew Stanford in WHA’s comments to DHS’s Medicaid Telehealth Policy Team. "Enabling patients receiving emergency department care to access services available through telemedicine will improve care for MA enrollees by making it easier for MA enrollees to access and receive emergency care closer to home."

WHA noted DHS’s intent that the draft update to Topic #510 is intended to be clarifications and minor changes to current policy and that Medicaid plans to consider broader updates to telehealth policy at a later date. While minor changes to the draft list of Medicaid-covered telemedicine services were included in the draft, WHA also encouraged the Team to further review its list of services to ensure no viable options for treatment via telehealth are excluded. The comment letter noted CMS’s new CY2017 list of Medicare telehealth services includes allowable codes that were not listed in the draft update to Topic #510.

"Advancing telehealth in Wisconsin is a shared objective of WHA and the Department as telehealth is an important tool to help further access to cost-efficient, high-quality care for Medicaid enrollees," wrote Stanford.

WHA also commented on newly included topics regarding Medicaid services for individuals in nursing homes and behavioral health services. WHA asked for additional clarity regarding certain telemedicine exclusions involving nursing home assessments and recommended special attention to behavioral telemedicine policies.

"With significant shortages of psychiatrists and substance abuse services in many parts of Wisconsin, telehealth is an important tool that can help provide better access to Medicaid enrollees with mental health and substance abuse access challenges," wrote Stanford. "We recommend the Department carefully review the allowable procedure codes for mental health and substance abuse telehealth services to ensure no viable options for mental health and substance abuse treatment via telehealth are excluded."

DHS indicated a final update to ForwardHealth Topic #510 will be published in the next several weeks.

This story originally appeared in the March 31, 2017 edition of WHA Newsletter