Medicaid Expands Telehealth Coverage: Opportunities and Challenges

April 18, 2020

With the advent of the COVID-19 crisis, telehealth has seen an unprecedented boom. While telemedicine is not a new concept, prior to the coronavirus pandemic it was certainly less popular than traditional in-office visits for many reasons, including patient/provider skepticism and healthcare regulations.[1] However, with the need to shift to telehealth, health systems like Geisinger Health in Pennsylvania are experiencing “a 500% increase in telehealth visits.”[2] This has been facilitated by Medicare and other commercial payors expanding into telehealth. Centers for Medicaid and Medicare Services (CMS) announced a toolkit on April 23, 2020, to facilitate this expansion for Medicaid and Children’s Health Insurance Program (CHIP) recipients.

The CMS toolkit is meant to provide guidance and recommendation to the states. Given the fact that each state sets its own Medicaid policy, the administration, coverage, and reimbursement of telehealth will also be governed at the state level. Some of the policy considerations outlined in the toolkit include:

  • Specifying types of services covered, places of service, types of eligible practitioners, and types of telehealth technology to be utilized
  • Allowing reimbursement to be set in the same manner as face-to-face visits
  • Including Managed Medicaid plans so that coverage extends to those beneficiaries
  • Enabling costs such as technical support, transmission charges, and equipment to be reimbursed to providers (any change to payment methodology would require a state plan amendment)
  • Altering state scope of practice laws to allow various healthcare providers to offer telehealth services
  • Providing flexibility for designated Federally Qualified Health Centers (FQHC) and Rural Health Center (RHC) to allow for telehealth visits

Access to Care Requires Access to Broadband Internet and Telecommunications Equipment

 Medicaid and CHIP recipients are least likely to have access to adequate phone and/or broadband services, making it difficult for them to take advantage of expanded telehealth services. Nationwide, only 60% of the population has in-home access to internet service that meets the Federal Communications Commission’s definition of broadband.[3] This affects both rural and urban areas While the CARES Act provides up to $200 million in telehealth funds, it is only for eligible providers, contains specific restrictions, and requires the recipient to submit reports and comply with audits.

For more information on telehealth and transaction advisory services pertaining to telehealth provision and equipment, we encourage you to contact one of our experts today.

Joe Aguilar 

Don Crawford 

Natalie Bell 

Robert Holland 


[1] “The Health 2020: Coronavirus means Americans are finally embracing virtual health care.” Cunningham, Paige W. The Washington Post. 8 April 2020.

[2] “How the COVID-19 pandemic is reshaping healthcare with technology.” Padmanabhan, Paddy. CIO. 27 March 2020.



The information provided herein is accurate as of the date of entry and relies on data available at the time of writing. Given the rapidly changing environment, the information provided is intended as a resource only and should not replace direct consultation of relevant laws, policies, and guidelines. HMS Valuation Partners is committed to ensuring that clients have accurate and up-to-date information and is closely monitoring any changes in policy and practice relevant to COVID-19.

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