In the beginning of March 2020, insurers across the country immediately began requesting that barriers to providing care be removed during the pandemic to help them more efficiently test and treat COVID-19 patients. However, on March 18, 2020, Congress passed the Families First Coronavirus Response Act, which required health insurance companies that offer individual and group health plans to waive cost-sharing charges for Food and Drug Administration-approved COVID-19 testing. While states were already responding to requests for insurers to waive cost sharing, the passage of this act required cost sharing for COVID-19 testing to be waived in all 50 states.
However, testing is not the only area where cost sharing is being waived. Cost sharing for telehealth, office and emergency room visits and even future COVID-19 vaccines is being handled differently by each state. Some states are only requiring testing to be waived (as mandated by the Families First Coronavirus Response Act), while others have required that cost sharing be waived for actions beyond testing. Most of these requirements were put into place in the beginning of March 2020, however, a few states have since expanded on the order. These states have required carriers to provide COVID-19 treatment with no additional consumer cost sharing, provide in-network and out-of-network testing and treatment with no cost sharing and extend their initial orders longer as the coronavirus continues to spread across the country.
With stay-at-home orders in place across the country and elective procedures and visits cancelled, states and insurers began to encourage and promote telehealth programs. The first act many states made with regard to their telehealth programs was to ensure that carriers’ programs were robust and able to meet demand. Many states also requested that carriers provide coverage for telehealth services on the same basis as in-person visits.
Most states have not expanded their telehealth-related orders since March or April. Across the board, states are mainly requiring the same elements of telehealth services: no cost sharing if the visit is related to COVID-19 and coverage provided at the same rates as in-person service. However, a small number of states have instituted broader requirements for telehealth services, including the coverage of out-of-network visits and removal of prior-authorization requirements.
While the COVID-19 pandemic has imposed temporary waivers, exceptions and changes to telehealth policy across the country, in most cases, these changes are only in effect through the end of either state or national emergencies. As shown in the maps below, private payer laws for telehealth reimbursement policies have expanded greatly in the past eight years, even before the COVID-19 pandemic. For Medicaid, all 50 states and Washington D.C. reimburse for certain types of live video telehealth services, but vary on their reimbursement policies for store-and-forward and remote patient monitoring (RPM).