TECH- Chances of State Medicaid Programs Bringing Telehealth Services Into ‘23 are High

MM Curator summary

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[MM Curator Summary]: Telehealth for BH remains the most likely contender for survival of any post-pandemic clawback.


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Medicaid officials of 44 states (including the District of Columbia) responded to a KFF survey about policies and trends relating to telehealth delivery of behavioral health services. Officials reported high utilization rates of telehealth services for behavioral health purposes since the beginning of the pandemic and plan to continue telehealth expansion permanently.

Telehealth seems to be a necessity when accessing behavioral health services for Medicaid users.

In 2022, behavioral health, especially mental health, remained a top service category with high telehealth utilization among Medicaid enrollees.

In a recent KFF survey, state Medicaid officials were asked about their telehealth delivery policies and trends when it came to behavioral health. Out of all U.S. states only 44 (including the District of Columbia) participated. Responses resulted in many seeking permanent adoption of pandemic-era telehealth policy expansions.

Early in the pandemic, all 50 states expanded coverage and/or access to telehealth services in Medicaid. Respondents of the survey stated they took at least one specified Medicaid policy action to expand access to behavioral healthcare through telehealth. For example, states expanded behavioral health provider types eligible to provide Medicaid services through telehealth. States also expanded categories of Medicaid behavioral health services eligible for telehealth delivery. Lastly, states newly allowed or expanded their audio-only services.

As of July 1, 2022, states were more likely to offer this audio-only services.

Audio-only coverage was reported to help facilitate access to care, especially in rural areas with broadband access challenges and for older populations who may struggle to use audiovisual technology.

While, many states reported high utilization of telehealth for behavioral healthcare after, some noted utilization trends among certain subgroups of Medicaid enrollees.

These trend subgroups include:

  • Geographic: With states most commonly reporting particularly high behavioral health telehealth utilization in rural areas compared to urban areas.
  • Demographic: These trends indicate behavioral health conditions are most prevalent among young adults and White people. In particular, some states reported younger enrollees (including children and non-elderly adults) were most likely to utilize telehealth for behavioral health care.
  • Temporal: States have frequently reported behavioral health telehealth use has declined from its peak earlier in the pandemic, but remains high compared to the pre-pandemic period. Future policy changes, such as to further expand or to limit telehealth flexibilities, may impact ongoing utilization.

Nearly all responding states found some of these trends by monitoring utilization in 2022. Many plan to begin doing so in 2023, which is important for the future of Medicaid telehealth policy for behavioral health as it relies on continued analysis of utilization and other data, as well as federal guidance.

As states continue and expand their monitoring, the results of these analyses may provide information that can inform policy decisions.

For example, the Bipartisan Safer Communities Act signed into law in June 2022 directs CMS to issue guidance to states on options and best practices for expanding access to telehealth in Medicaid, including strategies for evaluating the impact of telehealth on quality and outcomes, KFF said. CMS must then issue this guidance by the end of 2023.

The Consolidated Appropriations Act passed in December 2022 authorized additional telehealth provisions, such as requirements for Medicaid provider directories to include information on telehealth coverage and for CMS to issue guidance on how states can use telehealth to deliver crisis response services.