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Paul BaldwinA J.D. POWER SURVEY conducted in July of 2019 revealed that only 9.6% of the population had ever used telehealth to communicate with a healthcare provider over the previous year. The other side to what seems to be a pretty low adoption score is that those who have used telehealth are among its most enthusiastic supporters.

Experts make the analogy between telehealth and the adoption of mobile banking technology. Consumers tended to be somewhat slow to adopt that option, but once they had experienced it they took to it with gusto.

CMS (Centers for Medicare & Medicaid Services) defines telehealth (or telemedicine) as the exchange of medical information from one site to another through electronic communication to improve a patient’s health. Historically, the benefit has been covered by Medicare Part B and has been limited to Medicare beneficiaries who live in a designated rural area and when they leave their home to go to a clinic, hospital, or other designated facility for the service.

Medicare and Medicaid embraced telehealth slowly as regulators struggled with coding issues and the number and types of services that could be delivered by telehealth. Medicare Advantage organizations began using their discretion to encourage telehealth whenever practical. CMS began loosening the restrictions in 2019 to allow for virtual visits by beneficiaries with providers through virtual check-ins, where a patient initiates a contact with a provider through a patient portal.


Then came COVID-19. Emergency rooms are filled with highly contagious patients, and physician offices are forced to scale back to protect patients and staff from infection. Nursing homes have been forced to close their doors to nonresidents, and attending physicians find their schedules cannot accommodate nursing home visits. Assisted-living facilities have limited access by nonresidents while residents may have difficulty getting appointments for routine medical follow-up care and for new appointments.

The federal government has responded by requiring nursing facilities to limit access by nonresidents and by suspending the requirement for in-person physician consultations with residents, determining that telemedicine consultations would be an acceptable alternative. Assisted-living facilities are not regulated as healthcare facilities by the federal government, so state and local laws and regulations determine the level of access to healthcare providers.

As the healthcare system quickly became overloaded, CMS began allowing state Medicaid programs, through a Medicaid 1135 waiver, to pay for virtual visits with physicians, nurse practitioners, psychologists, clinical social workers and allowed providers to waive patient cost sharing. As of early April, more than 40 states had been granted Medicaid waivers to provide enhanced telemedicine services.

As you can imagine, the popularity of telehealth has skyrocketed. Suddenly, the slow but steady growth in the industry has been upended by an unprecedented demand for services. Telehealth companies have had difficulty in meeting the crush of requests for appointments as they scramble to add staff and bandwidth.


The missing element, at this point, is coverage for telepharmacy services to beneficiaries of Medicare and Medicaid. The reasons for this may be related to the lack of provider status for pharmacists under Medicare and the patchwork nature of state regulation of telepharmacy. About two-thirds of all states have laws and regulations that specifically authorize the operation of telepharmacy operations. Among those, many limit the operation of telepharmacy to rural areas and some prohibit the operation of a telepharmacy that is located near another pharmacy.

While the broad definition of telepharmacy includes remote dispensing, there appears to be an opportunity for pharmacists to provide counseling and drug regimen reviews through a telehealth portal. Enterprising pharmacies should consider proposing this type of service to Medicare Advantage programs where CMS is likely to allow the practice as a means of keeping beneficiaries out of hospitals.


Once the crisis is over — and it will eventually end — what will be the effect on telehealth in the United States? No one knows for sure, but we can imagine that the large numbers of consumers who have had a positive experience will find this a good alternative to in-person care and the industry will begin a new expansion. Those who found the process time-consuming and frustrating may abandon the concept and opt for the tried-and-true personal approach. The jury’s out on how this will change long-term care, but we should see more facilities begin to add telehealth to their service menu, even if only for the next crisis. CT

Paul Baldwin is a veteran healthcare policy and government relations executive. With 30 years of experience in pharmaceuticals and pharmacy, he is still an avid learner about what makes healthcare policy work for industry and for the public. Read more from him at his website, He can be reached at