The Massachusetts Medical Society (MMS) appreciates the opportunity to comment on a selection of bills before the Joint Committee on Financial Services related to telemedicine services. The Medical Society would like to be recorded in support of H.1002, H.991, and S.612.
Telemedicine technology has an opportunity to address some of the greatest challenges facing the health care system in Massachusetts, including access, quality, and cost of care. The technologies necessary to realize these improvements are currently available, and many physicians in the state are eager to incorporate telemedicine into their clinical care. However, impediments to the adoption and utilization of telemedicine persist as a result of uncertainties in health insurance coverage and reimbursement. This, in turn, undermines any potential benefits the Commonwealth’s health system and residents may reap related improvements in access to and value of care associated with the use of telemedicine technology.
Telemedicine directly addresses challenges of access facing Massachusetts patients by allowing them to see their physicians without the inconvenience—or impossibility—of traveling to the office. This technology can address inequities in access to care for patients who have difficulty traveling to a physician office because of location-, age-, disability-, and/or socioeconomic status-related challenges. Telemedicine can be particularly useful in expanding access to psychiatric care, allowing patients receive crucial treatment in the comfort of their home. Lastly, telemedicine reduces missed appointments and thereby increases the capacity and efficiency of physical workspaces.
Telemedicine can also improve the quality of care provided. Uses of the technology span from the most critical ICU patients who can be closely monitored via innovative technologies available from tele-ICU services to providing 24-7 access to urgent care telemedicine as an alternative to emergency department visits. Telemedicine can allow for better follow-up care after a procedure by allowing frequent, brief check-ins by physicians and nursing staff, and it can allow for greater care coordination, medication adherence, etc. Such services can also give providers a valuable glimpse into patients’ home lives, which can improve the therapeutic relationship. Many rigorous studies have demonstrated the increased quality of patients receiving telemedicine care. At Partners Healthcare, studies have shown improved quality outcomes for patients with congestive heart failure(1), and improved medication adherence when using pill bottle telehealth technologies(2). A large-scale study at the Veterans Health Administration showed significantly better care provided to veterans with a variety of chronic diseases(3).
The Massachusetts Medical Society believes that the single most important step that the legislature can take in facilitating telemedicine throughout the state is to require appropriate insurance coverage and to ensure proper reimbursement for telemedicine services. The coverage requirement–which would only apply to services that can appropriately be provided via telemedicine–ensures that services that would be covered if offered at an in-person visit would also be covered if provided more efficiently via telemedicine services. This is not a mandate to cover new services, but rather, a requirement to cover services across modalities, regardless of whether those services are delivered in-person or not. For these reasons, the Center for Health Information and Analysis has determined that a telemedicine bill with a coverage mandate would have a negligible impact on costs for insurers(4).
Coverage alone is not sufficient for facilitating an expansion of telemedicine, as many insurers have covered select telemedicine services, but have reimbursed physicians at a significantly reduced rate compared to rates for the same services provided in-person. These reduced telemedicine rates are not sustainable, and cover neither the overhead costs of the technology nor the physician time. With so many studies showing comparable quality outcomes for medical services provided via telemedicine and in-person, the reimbursement should not be substantially reduced simply because of a differing modality.
The Medical Society thus strongly supports parity in payment for telemedicine services so that reimbursement is equivalent to in-person services, when they are medically appropriate. That parity is needed to correct the inequities in access to care described above, as inadequate reimbursement for care provided through telemedicine limits access to high-quality care for vulnerable patients across the state of Massachusetts.
For these reasons, the Medical Society strongly supports H.1002, sponsored by Rep. Kate Hogan, which provides coverage for appropriate services provided by telemedicine, and which ensures that those services are reimbursed at a rate no less than the rates for the same services provided for in-person care. Importantly, this mandate would apply to the MassHealth program (in addition to commercial plans), as MassHealth is currently one of only three Medicaid programs in the country that does not robustly cover telemedicine services. The Medical Society also supports H.991 and S.612, sponsored by Rep. Golden and Senator Lewis. These bills all provide a comprehensive regulatory framework that will support providers’ ability to adopt and deliver services using telemedicine technologies by ensuring appropriate coverage for services and parity in reimbursement. H.991 and S.612 additionally calls for the creation of regulations to permit proxy credentialing and privileges for telemedicine providers consistent with federal Medicare Conditions of Participation standards. Proxy-credentialing allows the hospital or health care provider organization receiving the telemedicine services to rely on the privileging and credentialing decisions made by the hospital or entity providing the telemedicine services, provided certain requirements are met. Proxy credentialing would alleviate complications and administrative burden associated with the credentialing process by allowing hospitals and other entities to facilitate access to telemedicine and comply with the Conditions of Participation without incurring the full administrative burden associated with the traditional credentialing process. This could be particularly helpful for smaller or rural hospitals.
The Medical Society urges the legislature to take an important step in improving the access and value of medical care provided in Massachusetts by reporting out favorably legislation to ensure coverage and parity in reimbursement for services provided by telemedicine.
1 Kulshreshtha A, Kvedar J, Goyal A, Halpern EF, Watson AJ. Use of remote monitoring to improve outcomes in patients with heart failure: a pilot trial. Int J Telemed Appl. 2010;2010:870959. Epub 2010 May 19
2 http://content.healthaffairs.org/content/33/2/194.full
3 Darkins A, Ryan P, Kobb R, Foster L, Edmonson E, Wakefield B, et al.Care coordination/home telehealth: the systematic implementation of health informatics, home telehealth, and disease management to support the care of veteran patients with chronic conditions. Telemed J E Health. 2008;14(10):1118–26
4 Center for Health Information and Analysis, Mandated Benefit Review, October 2016, available at http://www.chiamass.gov/assets/docs/r/pubs/19/H2207-and-S507-Womens-Health-020719.pdf.
