MassHealth covers a robust array of medical, behavioral health, and other medically necessary services for members. Most MassHealth covered services have traditionally been provided in person, through face-to-face meetings between a member and a provider. Some services have long incorporated flexible delivery modalities, including delivery of services through audio or video technologies. These flexible delivery models enhance and expand the availability of services by allowing members to access services in a manner that more readily meets their needs. The delivery of healthcare services through audio or video technology is known as “telehealth.” Telehealth is not a service itself, rather, it denotes a modality for the delivery of an otherwise covered service.
MassHealth issued its first official telehealth policy effective January 1, 2019, which allowed for the delivery of certain behavioral health services through telehealth modalities. At the time the bulletin was issued, the overwhelming majority of MassHealth service providers did not utilize telehealth modalities, preferring traditional face-to-face delivery of services. However, in March of 2020, the [2019 coronavirus, or COVID-19] pandemic required nearly all providers of community-based behavioral health services (and many other health care services) to immediately transition to telehealth modalities for the provision of care and to not interrupt existing clinical treatment. The outpatient behavioral health workforce was required to pivot immediately to almost exclusively remote work. In some instances, this abrupt shift, necessitated by the COVID-19 emergency, came without the benefit of time for training or administrative and oversight support typical with the adoption of a novel care delivery modality.
As the public health emergency continued, the demand for behavioral health care increased rapidly, with unprecedented numbers of individuals requiring therapeutic intervention for behavioral health conditions. The crisis has been exacerbated by large numbers of staff and clinicians leaving the workforce. As a result, behavioral health providers have seen higher caseloads and more acuity of need among patients, all while managing staffing shortages and higher turnover.
As the full scope of clinical best practices and state and federal telehealth policy continue to evolve, providers have been working to adopt new policies, procedures, and practices to ensure member safety and privacy, while maintaining access to services for members in need. The workforce pressures faced by providers have presented challenges to investing administrative resources in staff training and other elements beyond pure service delivery.
Finally, industry standards relating to the delivery of services through telehealth modalities continue to develop and evolve. For example, in the spring of 2020 in Massachusetts, few, if any, electronic medical record software platforms included hard-coded fields to capture information regarding the delivery of services via telehealth. Since that time, however, commonly used platforms have started to include fields for providers to include information about telehealth encounters in medical records. Additionally, as providers become more fluent in integrating telehealth modalities into their work flows, understandings of clinical best practices continue to evolve.
When MassHealth’s initial telehealth policies were developed, there was limited industry adoption of telehealth modalities, and guidance for providers on best practices for delivery of services through this emerging modality in Massachusetts was scant. Since MassHealth telehealth policies were developed, MassHealth, like all healthcare payors and providers, has worked to keep abreast of and in step with industry updates and best practices. In response to this audit and as part of its efforts to keep its policies up to date with clinical and industry best practices, MassHealth has carefully reviewed its guidance regarding telehealth best practices with its clinical leadership at MassHealth’s Office of Clinical Affairs and issued revised telehealth guidance on October 19, 2022, to update and clarify its expectations for telehealth encounters and record keeping requirements. As discussed below, these changes respond to the [Office of the State Auditor’s] findings and reflect updated best practices for services delivered via telehealth.
|November 23, 2022