The LTSS (long-term services and supports) definition includes services and supports provided to patients with functional limitations and/or chronic diseases that have the key goal to support the patient's ability to live or work where they desire (including home, a worksite, a residential setting, a nursing facility, etc.).
To allow a consistent LTSS, the states with managed care organizations, prepaid ambulatory health plan (PAHP) and prepaid inpatient health plan (PIHP) have to develop and enforce the following standards:
- time and distance for each type of LTSS providers whom patients must travel to in order to receive services
- other network adequacy standards for each type of LTSS providers who come to patients to deliver care
When speaking about developing network adequacy standards, the rule binds the states to consider, at least, the list of 9 elements, and among them “the availability of triage lines or screening systems, as well as the use of telemedicine, e-visits, and/or other evolving and innovative technological solutions.”
The thing is, it's the only entry about telemedicine in this rule. This element was added only because of comments to the proposed rule, it wasn't initially there. Among the commenters were State Medicaid agencies, healthcare providers and associations, health insurers, advocacy groups, health care associations and society.
It seems like CMS underestimates the value that technology can bring. Moreover, there is not a single word about mHealth in the rule. Although it belongs to telemedicine, mHealth is its most evolved part, designed to bring in great care delivery improvements. It is especially important to regulate (at least to mention) mobile health solutions in respect to the benefits expected from this new rule, such as:
- improved health outcomes
- reduced unnecessary services
- improved beneficiary experience
- improved access
- improved program transparency which facilitates better decision making