Codifying Components of the Medicare 1135 Waiver

Stratis Health convenes a Virtual Health Sharing Group of health system telehealth directors, representing 11 health systems in Minnesota. Since 2017, the group discusses telehealth implementation progress, challenges, and priority topics. With the Coronavirus Disease 2019 (COVID-19) outbreak, the group increased meeting frequency to discuss strategies around the rapidly changing telehealth guidelines and approaches during the pandemic.

Stratis Health is conducting occasional brief surveys to capture snapshots of the expanding telehealth use in Minnesota. This telehealth snapshot focuses on telehealth policies, specifically the Medicare 1135 waiver.

The Medicare 1135 Waiver has dramatically expanded the use of telehealth services since March 2020. In April, Stratis Health conducted a survey of Virtual Health Sharing Group members, plus several other health systems, to gather feedback regarding which of the telehealth components in the Medicare 1135 waiver should continue permanently. Respondents included large and small health systems covering both urban and rural areas and several that operate in multiple states.

These survey results indicate in ranked order the priority Medicare 1135 Waiver components that should be continued:

  1. Maintain the expanded list of eligible telehealth practitioners that includes all those eligible to bill Medicare for professional services (includes physical therapy, occupational therapy, clinical social workers, and others)
  2. Originating site of telehealth visit can be patient home or residence
  3. Expanded geography allowed for all telehealth visits including both rural and urban settings
  4. Use of expanded list of 80+ telehealth available procedural codes
  5. Payment parity for audio-only telephone visits
  6. Use of Place of Service (POS) billing code where patient would have been seen
  7. Provider licensure flexibility to practice in every state (subject to state licensure rules)
  8. Audio-only virtual communications allowed for certain services
  9. Use of non-HIPAA compliant technology platforms

Health Systems survey respondents also suggested additional policy changes not currently part of the Medicare 1135 Waiver, which would support access and quality: including pharmacies as eligible telehealth clinicians and allowing FQHCs and RHCs as eligible originating sites.

What’s Next

Stratis Health will continue to convene the front-line leaders in telehealth in Minnesota, to support sharing and problem-solving, and to capture aggregate data and insight at points in time which can inform policy and programs at a state and federal level.