Opportunities Exist To Strengthen Evaluation and Oversight of Telehealth for Behavioral Health in Medicaid

WHY WE DID THIS STUDY

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 State evaluations and oversight of telehealth for behavioral health services as of January and February 2020, before the expansion of telehealth due to the COVID-19 pandemic. It provides a useful foundation to inform the Centers for Medicare & Medicaid Services (CMS) and State decisions about how to evaluate the impacts of telehealth on access, cost, and quality of behavioral health services and to strengthen oversight of program integrity. Evaluating the effects of telehealth on access, cost, and quality is particularly important in helping States make decisions about how to best use telehealth and about which populations benefit most from these services. Understanding States' efforts to oversee telehealth can help States protect their Medicaid programs. Further, States' expansion of telehealth during the COVID-19 pandemic has been largely on a temporary basis. As States consider making telehealth expansions permanent, States can use information in this data brief to help determine which services best support enrollees. This data brief is a companion report to a data brief that describes the challenges States reported with using telehealth to provide behavioral health services to Medicaid enrollees.

HOW WE DID THIS STUDY

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 efforts specific to managed care, the respondents focused on States' efforts to evaluate and oversee the use of telehealth more generally.

WHAT WE FOUND

While most States can identify which services are provided via telehealth, a few reported being unable to, limiting their ability to evaluate and oversee telehealth. In addition, only a few States have evaluated the effects of telehealth in their State; these States found increased access and reduced costs. Based on their own experiences, other States believe that telehealth increases access, has uncertain impacts on costs, and raises concerns about quality. Further, despite concerns about fraud, waste, and abuse, many States do not conduct monitoring and oversight specific to telehealth.

WHAT WE RECOMMEND AND HOW THE AGENCY RESPONDED

CMS and State efforts to evaluate and oversee telehealth are critical to meeting Medicaid enrollees' behavioral health needs and to safeguarding the Medicaid program from potential fraud, waste, and abuse. These efforts are particularly important as the telehealth landscape continues to evolve. Accordingly, we recommend that CMS: (1) ensure that the three States that are unable to distinguish telehealth from in-person services implement indicators to identify which services are provided via telehealth; (2) conduct evaluations, and support State efforts to evaluate the effects of telehealth on access, cost, and quality of behavioral health services; and (3) conduct monitoring for fraud, waste, and abuse, and support State efforts to oversee telehealth for behavioral health services. CMS concurred with the first recommendation but did not explicitly indicate whether it concurred with the other two recommendations.