Dramatic Changes to the Telehealth Benefit Due to COVID-19

Over the last week, the Centers for Medicare and Medicaid Services (CMS) has released several documents providing guidance and relief to healthcare organizations amidst the COVID-19 pandemic. First, CMS broadened access and greatly relaxed regulations around telehealth services for Medicare beneficiaries. Through this expansion, Medicare can temporarily pay providers for telehealth visits for Medicare beneficiaries across the entire country.

Shortly after this announcement, CMS released two telehealth toolkits to help healthcare organizations navigate the expanded benefit: the General Provider Telehealth Tool Kit and the End Stage Renal Disease (ESRD) Provider Telehealth Tool Kit. According to CMS, “each toolkit contains electronic links to reliable sources of information on telehealth and telemedicine, which will reduce the amount of time providers spend searching for answers and increase their time with patients. Many of these links will help providers learn about the general concept of telehealth, choose telemedicine vendors, initiate a telemedicine program, monitor patients remotely, and develop documentation tools. Additionally, the information contained within each toolkit will also outline temporary virtual services that could be used to treat patients during this specific period of time.”

What Does Expanded Telehealth Benefits Mean for Medicare Advantage Plans?

With the government and CMS directing healthcare providers to deliver only essential and emergency care to patients, those looking for non-essential services are suddenly unable to access the care they need.

With the expansion of telemedicine, Medicare beneficiaries are now able to receive various services through telehealth, including common office visits, mental health counseling, and preventive health screenings.

Since Medicare beneficiaries are at a higher risk for COVID-19 (i.e., coronavirus disease), telehealth allows them to visit their doctor from the comfort of their home, instead of going to a doctor’s office or hospital and putting themselves or someone else at risk. Patients will now be able to visit with providers using a wider range of communication tools, including telephones that have audio and video capabilities, making it easier for beneficiaries and doctors to connect without a face-to-face encounter.

This change also broadens telehealth flexibility without regard to the diagnosis of the beneficiary or the coverage they have. The expansion is effective for all Medicare beneficiaries, not just those with Medicare Advantage (MA) that may already have a telehealth benefit within their plan. It is available to all Medicare beneficiaries whether they have no coverage in addition to Medicare, a Prescription Drug plan, a Medicare Supplement plan, or an MA plan. Note that CMS has requested that MA plans communicate the specific policies and procedures on how to manage the flexibilities with relaxed telehealth regulations to both members and providers.

What Does Expanded Telehealth Benefits Mean for Providers?

Beyond the benefit to members, an increased emphasis on telehealth for non-essential visits will reduce the strain on the healthcare system overall, ensuring that doctor offices, urgent care centers, and Emergency Departments are available to treat the most urgent cases while reducing the risk of healthy beneficiaries contracting coronavirus disease by unnecessarily visiting a healthcare facility in person.

The expansion of the telehealth benefit will allow providers the opportunity to see more Medicare patients for non-essential—but still important—services, such as diabetes control, a patient not feeling well and is not sure what to do, prescription refill, and depression or anxiety brought on by isolation.


Although telehealth has many benefits, it is not without its complications. Providers were generally not prepared for the onboarding of a telehealth platform, the expense, the change to the structure of current practice operations, and the rapid timeline in which telehealth needs to be implement in order to effectively manage the most vulnerable members. Many of the specifics will require providers to quickly adapt (e.g., the requirement that telehealth calls be initiated by the Medicare patient; the different CPT and HCPCS codes).

As we look to the future beyond current COVID-19 flexibilities, in a recent proposed rule, CMS has also included the ability for plans to use telehealth services for certain specialties in order to expand their footprint into counties where they may not otherwise have been able to meet the network adequacy requirements. The success plans demonstrate in their ability to effectively care for and manage members remotely during this crisis may further support the expansion of relaxed adequacy requirements beyond those in the current proposed rule.

If you still have questions on how to navigate the expanded telehealth benefit, consider attending our upcoming virtual open forum on Thursday, March 26th, where the healthcare experts at GHG and analytics leaders at Pareto Intelligence will answer all of your specific questions across a variety of topics, including Marketing, Star Ratings, Risk Adjustment, Compliance, Network Adequacy and Development, Telehealth and Analytics.