The Wisconsin Commissioner of Insurance Nathan Houdek issued a
memo to health plans on Jan. 20, 2022, strongly encouraging health plans to maintain telehealth coverage parity and “minimiz[e] out-of-network barriers for patients seeking telemedicine (i.e., telehealth) services.” The letter also reminds health plans of their obligations to maintain an adequate provider network for telehealth services.
Commissioner Houdek serves as the state’s chief regulator of insurance and oversees the operations of the Office of the Commissioner of Insurance (OCI).
Speaking to telehealth coverage parity and COVID-19 impacts, Houdek wrote in the memo, “Where appropriate, health plan issuers are strongly encouraged to not deny coverage for a treatment or service provided through telehealth if that treatment or service is covered under the policy or plan when provided in person by a health care provider.”
Houdek noted the impact of COVID-19 on the capacity of health care facilities and a need for “robust” telemedicine programs to meet increased demand.
“Health plan issuers are reminded to review provisions in current policies regarding the delivery of health care services via telemedicine and ensure their telemedicine programs with participating providers are robust and will be able to meet any increased demand,” stated Houdek.
The memo also requested that health plans verify the adequacy of their provider networks to handle a potential increase in the need for telehealth services.
“If health plan issuers do not have sufficient telehealth providers in their network, health plan issuers are requested to develop a plan to address these shortfalls including making exceptions to provide access to an out-of-network provider at the in-network cost-sharing level,” stated Houdek. “Health plan issuers who lack access to telehealth services where in-person services are not available may be found by OCI to lack an adequate provider network as required by Wis. Stat. §§ 609.22 and 609.24 and Wis. Adm Code Ins 9.32.”
The memo from Commissioner Houdek can be found
here. If you have questions about this memo, contact either WHA General Counsel
Matthew Stanford or WHA Senior Vice President of Public Policy
Joanne Alig.