Telehealth & Reimbursement for MNT

Telehealth & Reimbursement for MNT

UPDATED SEPTEMBER 18, 2021

MA Division of Insurance

MA DOI is the state regulatory agency which creates and enforces regulations for the insurance marketplace in Massachusetts. MA DOI solicits public comments when updating existing regulations, and when there is ambiguity in a law as written and the agency must provide further guidance to insurers, the insured and organizations involved in providing services. In addition, MA DOI takes complaints from consumers on all matters related to the insurance marketplace, insurance companies and policies and organizations providing services to insured individuals.

Specific to telehealth, MA DOI is responsible to consumers, health care institutions and providers (public, private, state) and health insurers (MassHealth, Group Insurance Plan, third party/private payers). MA DOI held five telehealth information sessions between February and April 2021 to solicit comments on the implementation of telehealth provisions within Chapter 260 of the Acts of 2020, the law which established permanent coverage of telehealth mental health services, set time and reimbursement parameters for primary care and chronic disease management and called for a study of the use and cost of telehealth services during the pandemic.

For more information on the MA Division of Insurance:
https://www.mass.gov/orgs/division-of-insurance

For more information on Chapter 260 of the Acts of 2020:
https://malegislature.gov/Laws/SessionLaws/Acts/2020/Chapter260

View all comments submitted to MA DOI regarding telehealth provisions here:
https://www.mass.gov/service-details/telehealth-information-sessions

 

Telehealth FAQs

Can nutrition visits still be provided via telehealth?

Governor Baker announced the end of the emergency order initially put in place on March 10, 2020, which provided coverage + payment/rate parity for telehealth services via all types (modalities) of communication, including telephone, on June 15, 2021. Per the telehealth law which took effect on January 1, 2021, we have 90 days from June 15, 2021 for continued payment/rate parity for all types of telehealth services via all types of communication. As of September 13, 2021, there is no guarantee of rate parity for nutrition services provided by telehealth.

View MA DOI update on telehealth provisions here.

Is this decision final?

Not yet. There is a clause that allows for coverage + payment/rate parity for "chronic disease management" for two years from the date the law took effect (January 1, 2021 through December 31, 2022). However, it is unclear if MNT could be covered under the "chronic disease management" clause. We are still awaiting regulations from MA DOI as the law as written is ambiguous and does not mention MNT, nutrition services, or RDNs/LDNs specifically.

What is MAND doing to help advocate for ongoing coverage of and payment/rate parity for nutrition services provided via telehealth?

MAND submitted written comments to MA DOI as part of the agency’s virtual information sessions for organizations and associations impacted by telehealth provisions in the telehealth law. In addition to submitting comments, MAND requested and was granted a meeting with MA DOI staff. 

For this meeting, MAND highlighted the following: (1) The academic and professional requirements to qualify for the ‘RDN’ credential; (2) continuing professional educational requirements of RDNs; (3) MAND’s work with the legislature to pass the law creating the voluntary practice license and Licensed Dietitian/ Nutritionist (LDN) designation; (4) medical nutrition therapy (MNT) and its use, effectiveness and cost-effectiveness in disease prevention, management, and treatment; (5) costs of chronic disease in the U.S. and in MA; and (6) how chronic conditions are contributing to poor COVID-19 outcomes, as evidenced by over a year of data. 

Regarding MNT, we described: (1) RDNs’ work in a variety of settings to prevent, manage and treat a variety of chronic conditions; (2) Medicare’s coverage of MNT for certain chronic conditions via secure video-conferencing services in the outpatient setting without copay since 2011; and (3) MassHealth’s and many third-party payers’ coverage of MNT, including in the private practice setting, most often with copay. 

We discussed barriers to the utilization of MNT services prior to the pandemic, including: (1) lack of awareness of the benefits of MNT; (2) lack of health insurers’ coverage of MNT; (3) the inability to locate or travel to and/ or costs associated with travel to the location of qualified dietitians; (4) patients’ and dietitians’ lack of appropriate secure videoconferencing tools; and (5) restrictive pre-COVID telehealth requirements. 

We next described the benefits to patients after the allowance for expanded means of providing MNT via telehealth since the declaration of the state of emergency in March 2020 (e.g., audio-only): (1) reduced mobility and transportation and related cost barriers faced by patients; (2) reduced “no-show” rates; and (3) increased access to MNT, especially among patients with limited or no broadband or without laptop, tablet or smart phone. We underscored that receiving MNT is especially important for reaching those most at-risk patients who suffered from chronic health disparities even prior to the pandemic.

View MAND’s written statement to MA DOI here.

What is the next step?

We are still awaiting regulations from the state, after which there will be another period allowed for comments. MAND will continue to provide input advocating for continued coverage for nutrition visits via telehealth.

I am a dietitian in private practice and I have relinquished my office space during the pandemic and now practice by telehealth exclusively. How should I proceed?

Although the specifics of the coverage of nutrition visits provided via telehealth are still unclear at this point, per MA DOI credentialed providers need to offer both in-person appointments and telehealth appointments in order to remain in compliance with many of the insurance providers’ contracts. Private insurers may have specific requirements related to in person vs remote appointments. You should review the updated telehealth information on insurance companies’ websites for credentialed providers.

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