Chairman Brady and Representative Neal:
On behalf of the Association for Community Affiliated Plans (ACAP), I am writing to express our support for H.R.3727 that will include additional telehealth services for purposes of MA organization bids.
ACAP represents 60 not-for-profit community-based Safety Net Health Plans located in 26 states. Our member plans provide coverage to almost seventeen million individuals enrolled in Medicaid, Children’s Health Insurance Program (CHIP) and Medicare Advantage Dual-Eligible SNPs. Nationally, ACAP plans serve almost half of all Medicaid managed care enrollees. Twenty-four of our plans are D-SNPs, and 14 of our plans participate in the Financial Alignment Demonstration, accounting for approximately 30 percent of all enrollment in the Demonstration.
ACAP supports the legislation as it would allow MA plans to include telehealth in their annual bids and measures to encourage plan innovation with telemedicine. ACAP’s Medicaid plans are using telehealth in innovative ways that improves care coordination and access to care. We support permitting MA plans to include telehealth services in their annual bids, and we support permitting MA plans to include telehealth services in their bids that are not currently allowed under traditional Medicare, such as remote monitoring. Telehealth is an area where plans and states are currently innovating. For example, some states have formed workgroups to identify which telehealth services should be permitted under Medicaid. Flexibility for MA plans on telehealth would help align telehealth initiatives between Medicare and Medicaid. When making changes on areas that overlap with Medicaid, such as telehealth, Congress should direct the Secretary to be mindful of harmonizing requirements between Medicare and Medicaid. ACAP also believes that MA plans should be able to use telehealth services to comply with network adequacy requirements in certain instances, such as in rural areas, or in instances of shortages of a certain provider type, such as a particular specialist.View the full article »