Congressional Statement on Legislative Proposals to Support Patient Access to Telehealth Services
Transcarent shared a Statement for the Record for the House Energy & Commerce Committee Hearing on “Legislative Proposals to Support Patient Access to Telehealth Services.” Our VP Government Affairs Leslie Krigstein outlines the immediate actions Congress should take to improve access to telehealth and virtual care for employer populations and why Transcarent supports these overarching policy priorities.
April 10, 2024
Leslie Krigstein, VP, Government Affairs, Transcarent
Improved access to telehealth and virtual care for employer populations is essential to delivering high-quality, cost-effective health and care to Americans. Our team at Transcarent encourages Congress to consider several general policy principles that that would allow more people to reliably access telehealth and virtual care services, when and how they need them.
At Transcarent, we believe:
Telehealth policies should be modality-neutral, allowing the patient and their physician to determine if a particular modality meets the standard of care.
Physicians should be able to practice telehealth across state lines.
Telehealth and virtual care should improve health inequities and accessibility of healthcare, including for those that are not native English speakers.
Employers should be able to offer telehealth as an excepted benefit to part-time and seasonal workers, as well as those not on their group health plan as a means to expand access to high-quality, affordable care.
Employers should be allowed to offer telehealth and virtual care services to those on high-deductible health plans without requiring individuals to first meet their deductible.
We are committed to making it easy for people to access high-quality, affordable health and care; and will continue to advocate for policies that support Americans having equitable access to the care they need. Please read our official Congressional Statement for the Record below.
Statement for the Record
House Committee on Energy and Commerce
Subcommittee on Health
Hearing on, “Legislative Proposals to Support Patient Access to Telehealth Services”
April 10, 2024
About Transcarent
Transcarent was founded to change the healthcare status quo and offer greater choice and control for those that pay for care, including healthcare consumers (our Members) and employer-sponsored group health plans.
As the One Place for Health and Care, Transcarent supports self-insured employers by making it easy for people to access high-quality, affordable care. With a personalized app tailored for each Member, an on-demand care team, and a connected ecosystem of high-quality, in-person care and virtual point solutions, Transcarent eliminates the guesswork to guide Members confidently to the right level of care. Transcarent Members have access to care through the clinicians in Transcarent’s affiliated virtual clinic as well as from high-quality providers in their local communities.
Transcarent is committed to helping employers and their employees cut through the complexity of the healthcare system and the benefits landscape. We believe that properly aligned incentives and easy access to high-quality care is the foundation for accomplishing this. It results in a measurably better experience, improved health, and lower costs for individuals and their employers.
As evidenced during the COVID-19 pandemic, virtual care and telehealth were critical for millions of Americans and have proven to be an invaluable tool to ensure ongoing access to high-quality, affordable care. Data supports the value of telehealth and virtual care services for all Americans. Increased flexibility and enhanced access mean increased preventive care and early detection, translating to earlier treatment of conditions, and mitigating the need for higher acuity care.
The Transcarent Clinic
Through the Transcarent Clinic, Transcarent’s affiliated virtual clinic, Members receive on-the-go high-quality care on their terms for their most frequent and fundamental health needs through the ability to immediately chat with a doctor via text or video.
By removing wait times and giving them the answers they need when they need them, we’re helping Members avoid costly and inefficient emergency department and urgent care visits. Personalized support during and between visits makes it easier for Members to stay on top of preventive care screenings, referrals, and post-visit care. Additionally, our flexible, discreet chat or video modalities enable Members to access care without the need for a quiet place.
While some may question the value of virtual care encounters, the Transcarent Clinic is proving time and again that our clinicians are providing high-quality care while saving consumers and employers on their healthcare expenses. When we say “high-quality” we mean it. Here’s one example. Transcarent’s antibiotic stewardship commitment includes an active review of our prescribing practices and auditing of visits with antibiotic prescriptions. This explains why our antibiotic prescription rate is 22.8 percent as compared to the national benchmark of 37 percent1 and our steroid prescription rate is just .36 percent compared to the national benchmark of 11.8 percent2. Despite the presumption that less prescriptions correlate to unsatisfied patients, 96 percent of our Members rated the Transcarent Clinic with 5 stars for a 4.8/5 satisfaction rating.
We are also actively saving consumers and employers costs while still achieving great outcomes. Here are some examples:
$263 cost reduction per visit based on average cost for alternative options and Member utilization of virtual primary care3
93 percent resolution rate for virtual clinic visits4
45 percent reduction in emergency room (ER) and urgent care visits5
Overarching Policy Priorities
There are several general policy principles we believe Congress should consider to ensure that more Americans can reliably access telehealth and virtual care services, when and how they need them.
Transcarent believes:
Telehealth policies should be modality-neutral, allowing the patient and their physician to determine if a particular modality meets the standard of care.
Physicians should be able to practice telehealth across state lines.
Telehealth and virtual care should improve health inequities and accessibility of healthcare, including for those who are not native English speakers.
Employers should be able to offer telehealth as an excepted benefit to part-time and seasonal workers, as well as those not on their group health plan as a means to expand access to high-quality, affordable care.
Employers should continue to be allowed to offer telehealth and virtual care services to those on high-deductible health plans (HDHPs) without requiring individuals to first meet their deductible.
Modality-Neutral Approach
The modality (video, audio-only, text-based) used to deliver care should be determined by the patient and their physician and should be held to the same standard of care as services provided in-person. Telehealth should not be limited to any specific technology if it is safe, effective, appropriate, and able to be fully integrated into clinical workflows.
The growth of text-based care, which, with the right systems and tools, is broadening access to telehealth and virtual care. Not everyone has real-time video capabilities due to lack of broadband or the lack of a private space in which to speak with a physician, but access to text is common with 97 percent of Americans owning a cellphone6. When we asked people delivering packages, stocking shelves, and working in factories, ‘what worked best for them,’ they all said the same thing: make it simple to use, make it fast, and make it available whenever I want it. At Transcarent, that means you can access care on your phone, by text, with no wait times, 24 hours a day, 365 days a year. Congress should not seek to predefine how care is delivered; instead, this should be left to the physician to determine if the standard of care can be met using a particular modality.
Licensure Portability
Congress should act to ensure that access to care and care continuity are not hindered simply based on the physician and patient being in different states. Federal, and state, policies should ensure efficient licensure options exist not just during public health emergencies, but beyond, as workforce shortages and scattered expertise have and will continue to exacerbate health inequity.
Just as a patient may live in one state and drive to a hospital or physician office in another, so too, should patients be able to see their physician virtually regardless of where they live. This is especially valuable for ongoing relationships with specialists or surgeons after a procedure or treatment that may have warranted significant travel but can more efficiently be maintained through virtual follow-ups.
Improving Health Equity and Accessibility
It is important to ensure that all healthcare services are not just high-quality and affordable but are also accessible for all who need them, regardless of what language they speak. Transcarent supports the SPEAK Act (H.R. 6033,) to improve healthcare technology, including telehealth and other consumer resources for non-English speakers.
Telehealth as an Excepted Benefit
Transcarent strongly supports the bipartisan legislation the Committee advanced in 2023 that amends the Public Health Service Act, Employee Retirement Income Security Act (ERISA,) and the Internal Revenue Code of 1986 to treat telehealth services as excepted benefits, the Telehealth Benefit Expansion for Workers Act (H.R. 824).
The bill would allow employers to continue to offer workers stand-alone telehealth benefits, similar to a dental and vision plan, and onsite medical clinics, in addition to traditional healthcare plans. If enacted, it would build upon ERISA to enable all workers, including part-time and seasonal workers, to access telehealth benefits. This bill would be a continuation of the pandemic policy established by the Departments of Labor, Health and Human Services (HHS) and Treasury for employers wishing to provide telehealth or other remote care services to employees ineligible for any other employer-sponsored group health plan for the duration of the public health emergency.
Because this flexibility was not extended in a timely fashion, access to telehealth for some workers is no longer available. As H.R. 824 continues to make its way through the legislative process, interim action is needed so that access to critical telehealth services can be restored. We encourage the Committee to advocate for the inclusion of a multiyear extension of the PHE (Public Health Emergency) non-enforcement policy in the next health-related package that moves through Congress.
Pre-deductible Telehealth Coverage
We encourage Congress to swiftly enact The Telehealth Expansion Act (H.R. 1824) to deliver more high-quality, affordable care to hardworking Americans ahead of its scheduled expiration at the end of 2024. Reaching the deductible threshold of at least $1,600 for an individual and $3,200 for a family can create a significant financial strain. Given that more than half of all private sector workers were enrolled in a high-deductible health plan (HDHP) in 2021, this policy makes it easier for many American workers to utilize telehealth services that improve ease and access to care and reduce expensive ER and urgent care visits.
The Future of Health and Care Delivery
Telehealth is a proven, high-quality, and cost-effective means to connect Americans to the care they need when they need it. It is a service that is essential for vulnerable populations and the approximately 30 million Americans residing in health deserts7. Removing access to this care can serve to exacerbate the current disparities in the accessibility and affordability of health and care for all Americans.
Today, we have more technology at our disposal than ever before. We can bring care into the home, we can facilitate access to world-renowned specialists from one coast to the other, we can better predict individuals at-risk for certain conditions and we can personalize care plans to ensure optimal outcomes. We have the tools to improve access and bend the cost curve, now we need to remove the policy barriers so we can use them. We appreciate the Committee’s consideration of the importance of not only continuing but expanding access to high-quality, affordable telehealth and virtual care services for all Americans.
1 mHealth Intelligence, https://mhealthintelligence.com/news/vendor-affiliated-telehealth-providers-prescribe-antibiotics-more-often
2 Centers for Disease Control and Prevention (CDC), https://www.cdc.gov/antibiotic-use/stewardship-report/2020.html
3 Determined using alternative care responses, Post-visit survey, Mar 2021 - Mar 2023
4 Transcarent Book of Business
5 Transcarent Book of Business
6 Pew Research, https://www.pewresearch.org/internet/fact-sheet/mobile/