Brief: Barriers & Challenges to FQHC Use of Telehealth for Substance Use Disorder

An Examination of Policies Affecting FQHCs Pre- and During the COVID-19 Emergency

Prior to March 2020, opioid use disorder (OUD) was the most prominent national public health concern in the United States classified as a nationwide epidemic and urgent public health issue by the Department of Health and Human Services (HHS). 

Funded by the National Institute of Health Care Management (NIHCM), this issue brief from PHI’s Center for Connected Health Policy explores policy changes that need to be made in order for federally qualified health centers (FQHCs) to utilize telehealth to address the opioid crisis.

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FQHCs often serve as the first line of defense in rural and underserved communities, and many clinics were looking to telehealth to help address the OUD crisis and deliver Medication-Assisted Treatment (MAT), a best practice treatment for opioid addiction which combines medication and behavioral therapy. However, because of complex policy barriers, many FQHCs find themselves restricted from establishing a telehealth program to treat people with OUD.

The research for this study began in early 2020, and focused on five states with high incidents of OUD and where entities within the state had received funding for substance use disorder projects from the U.S. Health Resources Services Administration (HRSA). The five states selected included: 

• Kentucky
• Maine
• Maryland
• Ohio
• Pennsylvania 

CCHP conducted key informant interviews with Medicaid representatives, FQHC staff and primary care provider associations, as well as conducted a thorough analysis of each states’ laws, regulations and Medicaid policies pertaining to the intersection of telehealth, OUD treatment and FQHC policy. The most significant barriers included Medicare and Medicaid prohibitive reimbursement rules as well as the difficulty of navigating prescribing laws and regulations on both the federal and state levels. 

When COVID-19 hit in mid-March and telehealth was the only way to keep patients safe at home while still accessing healthcare services, longstanding policy barriers were removed in a matter of days with subsequent revisions further expanding telehealth access following in the subsequent weeks. In response, CCHP conducted a secondary analysis of the policies that have impacted FQHCs’ ability to deliver MAT via telehealth during the COVID-19 Public Health Emergency (PHE) and beyond. Although many of the policy barriers originally identified in CCHP’s initial research and interviews have been temporarily resolved, their future remains uncertain. Some, including the allowance for the home to be an eligible originating site, as well as expansions in eligible providers (including FQHCs) and services are likely to remain in some form, while others are less so, such as relaxation of HIPAA requirements.

The issue brief provides a comparison of reimbursement and prescribing policies both prior to and following the onset of the COVID-19 emergency. It also provides a chart on when the policy is set to expire (as of the time of writing the issue brief) and what it would take to make each policy change permanent. Even with the expansions for telehealth made as a result of COVID-19, some barriers still remain for FQHCs delivering MAT services via telehealth, including the different rate FQHCs receive for delivering telehealth services compared to their normal PPS rate, as well as issues around broadband connectivity, patient and provider education, and liability coverage.

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Originally published by Center for Connected Health Policy