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States Reported Multiple Challenges With Using Telehealth To Provide Behavioral Health Services to Medicaid Enrollees

See also: Opportunities Exist To Strengthen Evaluation and Oversight of Telehealth for Behavioral Health in Medicaid OEI-02-19-00401


States are increasingly relying on telehealth to provide behavioral health services to Medicaid enrollees. Before the COVID-19 pandemic, telehealth was an important tool for States to increase access to behavioral health services for enrollees in rural or underserved areas with provider shortages. During the COVID-19 pandemic, States expanded their use of telehealth to help meet the needs of enrollees while also reducing the risks from community spread of the virus. As the Nation confronts the psychological and emotional impact of COVID-19, the use of telehealth will be important in addressing behavioral health needs for Medicaid enrollees.

This data brief provides insight into States' challenges as reported in January and February 2020, before the expansion of telehealth due to the COVID-19 pandemic. It provides a useful foundation for the Centers for Medicare & Medicaid Services (CMS) and States by highlighting longstanding challenges with the use of telehealth that existed prior to the additional challenges caused by the pandemic. Understanding States' challenges with using telehealth to provide behavioral health services can help States improve their Medicaid program and assist enrollees with accessing needed care. Further, States' expansion of telehealth during the COVID-19 pandemic has been largely on a temporary basis. As States consider making telehealth expansions permanent, they can use information in this data brief to develop effective programs and troubleshoot challenges in implementation. This data brief is a companion report to a data brief that describes the extent to which States evaluate the effects of telehealth on access, cost, and quality of behavioral health services and the extent to which States oversee telehealth for fraud, waste, and abuse.


States commonly provide behavioral health services to Medicaid enrollees through managed care organizations. We conducted a survey of State Medicaid Directors from 37 States that provide behavioral health services via telehealth through managed care organizations. We also conducted structured interviews with relevant stakeholders. While we asked about challenges specific to managed care, the respondents focused on States' challenges with using telehealth more generally.


Most States reported multiple challenges with using telehealth, including a lack of training for providers and enrollees, limited internet connectivity for providers and enrollees, difficulties with providers' protecting the privacy and security of enrollees' personal information, and the cost of telehealth infrastructure and interoperability issues for providers. Some States also reported other challenges, including a lack of licensing reciprocity and difficulties with providers obtaining informed consent from enrollees. These challenges limit States' ability to use telehealth to meet the behavioral health needs of Medicaid enrollees.


CMS has an important role to play in facilitating the exchange of information among States to improve the use of telehealth for behavioral health services. Sharing information among States will help ensure that States realize the benefits of telehealth and make informed decisions about how to address challenges with using telehealth. We recommend that CMS share information to help States address the challenges they face with using telehealth. This information could include examples from States that describe how they have responded to these challenges. It could also include best practices from States and information about working with other State and Federal partners. Further, CMS could collect information from States detailing their experiences and lessons learned in response to the COVID-19 pandemic that address these challenges. CMS concurred with our one recommendation.