People with disabilities or medical, behavioral, and developmental conditions that otherwise qualify them for Home and Community Based Services (HCBS), referred to as HCBS eligible members experience disproportionate barriers to accessing healthcare and medical services across all settings, including telehealth. Telehealth is uniquely able to prevent or reduce risks of costly service utilization, institutionalization, and/or premature death. For example, people with intellectual and developmental disabilities (I/DD) are ten times as likely to expire during a COVID infection than those without IDD because they are unable to self-assess and report, and their support providers are unable to observe health indicators and early warning signs compared to their non-HCBS member counterparts.

 

Pg 6 of 22, Remote Patient Monitoring (RPM) eligiblity criteria excludes members without 2 or more recent hospitalizations or ER visits, which represents a disproportionate healthcare access barrier for HCBS eligible members. Their risk of institutionalization is significantly greater after even one ER visit compared to non-HCBS eligible members. Furthermore, HCBS eligible members are more likely to have cognitive conditions that interfere with their ability to effectively self-report change in status or to initiate medical attention early enough to prevent avoidable and costly negative outcomes. Please consider not only allowing, but promoting RPM for HCBS eligible members.

Pg 12 of 22, Telehealth Equipment and Technology. Without adequate funding and access to telehealth equipment and technology, HCBS eligible members will continue to experience significant administrative barriers to accessing telehealth services that can prevent or mitigate risks of ER visits, hospitalization, institutionalization, and premature death. HCBS members need specialized or adaptive equipment and technology to access telehealth, which is only allowable for adults age 21 and older if it meets criteria for durable medical equipment (DME) under the state plan or assistive technology (AT) under HCBS; and for children if it meets criteria for EPSDT. Please consider additional guidance that will allow state plan, HCBS, and EPSDT service authorization of equipment and technology necessary for medically necessary telehealth services as defined in this manual.