Making Telemedicine Permanent in Rhode Island
The Mental Health Association participated in all meetings of the Health Insurance Commissioner’s Telemedicine Work Group. Our task was to make recommendations as to how telemedicine could be implemented if made permanent in Rhode Island, per pending legislation. Commissioner Marie Ganim and her staff facilitated the rich dialogue.
MHARI submitted in writing the following comments and proposed revisions to the final draft of the Work Group’s recommendations.
● Because data demonstrates that behavioral health providers are already under-reimbursed for provided services, we strongly support the recommendation related to telemedicine payment and program integrity, that states: “…telemedicine behavioral health services should be paid at the same rate as in-person regardless of modality.”
● While telemedicine provides an opportunity to expand access to a more diverse network of BH providers, it should be strongly recommended via the work group that the State make an overt effort to build out our state’s network of more culturally and linguistically diverse out-patient behavioral health providers. We must avoid becoming dependent on out-of-state telemedicine companies that might undercut Rhode Island’s existing BH provider network by offering less expensive services that could result in the unintended consequence of pushing out locally based providers.
● The recommendations should state that to accurately and fairly evaluate costs, it is necessary to assess the long-term impact of such interventions. While higher rates of utilization of outpatient services may increase costs in the short-term, they decrease costs in the long-term because many medical and behavioral health crises will be avoided, thus reducing utilization of more costly emergency services, inpatient hospitalization, and residential treatment. The recommendations should reflect this.
● The work group recommendations should offer more specificity related to the recommendation for a measurement strategy to effectively evaluate performance, especially as it relates to the goals of improving access, reducing disparities, and ensuring quality and safety.
MHARI will continue to be on the frontlines fighting for the passage of the legislation in 2021 to make telemedicine permanent, accessible and affordable to all Rhode Islanders.
