Avoiding the Telehealth Cliff: Making Telehealth Expansion Permanent

By now, I think we have all heard about the surge of temporary waivers, relaxations of Medicare coverage restrictions, regulatory changes and flexibilities, and governors’ orders allowing for the expansion of telehealth during the COVID-19 Public Health Emergency (PHE).

This is all great news for telehealth – for now. Medicare telehealth services increased by 11,718 percent between March and April, and other payers are reporting similar increases. But what happens when the PHE is over? And when will the PHE be over?

So far, the Health & Human Services (HHS) Secretary has renewed the PHE once, in April, for 90 days. HHS has announced its intent to renew it again this month, meaning the PHE would then expire October 21, unless renewed again or declared over before that date.

I think that, in all likelihood, the PHE will continue being extended for at least a year. Seems like an impossibly long time, but compare it to the Zika PHE, which lasted nearly nine months, and the H1N1 PHE, which lasted nearly a year.

Even though the end of the PHE may not be imminent, there’s still a problem. When it does come, the end of the PHE means an abrupt termination of all those temporary changes that are currently making telehealth accessible and sustainable: The Telehealth Cliff.

What would have to happen to extend these emergency telehealth actions and avoid the cliff? That depends on who has the authority to change them. Both the American Hospital Association and the Center for Connected Health Policy (CCHP) have published lists of the federal-level legal and regulatory changes during the PHE and what actions would be needed to make them permanent.

So, are any of those actions taking place? Signs are positive! There’s been as much movement in the past month calling for extensions of the telehealth expansions as there was at the start of the PHE to create the expansions.

This is only a partial list. Momentum is building!

States are taking action too – you can track their legislative progress on the CCHP website.

Meanwhile, CMS has already used its regulatory authority to make some telehealth coverage permanent for home health care providers, and has told us to watch for its annual proposed Physician Fee Schedule (PFS), which normally comes out in July. There have been hints that the proposed PFS will include permanent expansions to Medicare telehealth reimbursement.

I strongly urge you to read the proposed PFS, when it’s posted, and comment with your telehealth experiences and outcomes during this period of unprecedented telehealth coverage. Your input could ultimately help us avoid the Telehealth Cliff.


Note: This blog was current as of June 14; change is continuing at a rapid pace. You can find up-to-date details on COVID-19 telehealth waivers and flexibilities on our Telemedicine COVID-19 Resources web pages.

About the Author

Nancy S. Rowe's picture

Nancy Rowe is Associate Director for Public Policy and Outreach for the Arizona Telemedicine Program (ATP) and Southwest Telehealth Resource Center (SWTRC), where she is a resource and frequent presenter on telehealth policy and reimbursement. Before joining the ATP, Ms. Rowe was director of telemedicine for Northern Arizona Regional Behavioral Health Authority (now Health Choice Arizona) for more than 12 years. She is a member of the Center for Telehealth and eHealth Law Advisory Board, a past chair of the American Telemedicine Association (ATA) Business and Finance Special Interest Group and a workgroup member for the ATA telemental health guidelines.

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