2024 Telehealth Studies
Background
The Maryland Health Care Commission (MHCC) was required by Chapter 382 (Senate Bill 534), Preserve Telehealth Access Act of 2023 and Chapter 291 (House Bill 1148), Behavioral Health Care - Treatment and Access (Behavioral Health Model for Maryland) of the 2023 Laws of Maryland to study and make recommendations regarding the delivery of somatic and behavioral health services through audiovisual and audio-only telehealth technologies, including payment parity for the delivery of health care services through audiovisual and audio-only technologies.
The impetus for the study provisions in law are based on recommendations included in MHCC’s final report (December 2022) required by Chapter 70 (House Bill 123) and Chapter 71 (Senate Bill 3) Preserve Telehealth Access Act of 2021 of the 2021 Laws of Maryland. The law tasked MHCC with conducting a study on the impact of telehealth as it relates to use of audio-only and audio-visual technologies in somatic and behavioral health interventions. The study was informed by an MHCC-convened Telehealth Policy Workgroup (workgroup) in 2020 that discussed telehealth policy changes implemented in response to the COVID-19 public health emergency; the workgroup generally concluded there was a need to study quality and cost of telehealth by examining trends in access and utilization of audio-only and audio-visual technologies (see final report, February 2021).
The MHCC issued two Request for Proposals in October 2023 and November 2023 to obtain a contractor with subject matter expertise in telehealth and actuarial science methods to assess the adequacy of payer reimbursements, among other things. In December 2023, Milliman, Inc. was competitively selected to complete study activities, including an analysis using private payer, Medicaid, and Medicare data from MHCC’s All Payer Claims Database (APCD).
Milliman prepared two technical reports on its findings: Technical Report One compares the average allowed cost and clinical intensity for services provided in-person and via telehealth; Technical Report Two compares reimbursement rates as a percent of the Medicare Physician Fee Schedule for somatic and behavioral health services delivered in-person and via telehealth. Milliman’s findings guided development of three recommendations that center on preserving telehealth coverage and reimbursement in a final report submitted to the General Assembly. A high-level summary of the findings and recommendations is available here; a data supplement from Milliman’s analysis is available here.
Updates
November 12, 2024
The Commission approved the telehealth study recommendations report at its October 17, 2024 public meeting. The report was submitted to the General Assembly. The recommendations are based on study findings and stakeholder feedback and are intended to inform the debate on payment parity and support health policy goals.
September 10, 2024
Milliman drafted two technical reports based on findings from its analysis using private payer, Medicaid, and Medicare data from the APCD. The technical reports informed drafting of telehealth coverage and reimbursement recommendations. Stakeholder viewpoints and telehealth policy changes adopted by the Centers for Medicare & Medicaid Services were considered in preparing draft recommendations and supporting rationale in a final report that will provide guidance to the Maryland General Assembly on how to approach future legislation. More information on the final report will be made available in the coming weeks.
May 10, 2024
Milliman completed an analysis of evaluation and management (E/M) codes to identify the distribution of services provided (2019-2023). E/M codes for behavioral health and primary care were identified as the foundation for a framework to compare reimbursement rates as a percent of the Medicare Physician Fee Schedule. An examination of providers time and intensity to deliver care virtually and in-person is underway.
March 5, 2024
Milliman scoped out draft parameters for the methodology that will guide development of a framework for assessing payment parity. A provider roundtable was convened virtually on February 27, 2024 to solicit informal feedback on the proposed methodology and a preliminary list of codes for primary care and behavioral health outpatient services to be used in the analysis. The list of participants is available here; a recording of the discussion is available here.