Illinois Mental Health Counselors

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State Licensing Regulation on Telehealth

Current licensing laws don’t provide enough guidance as to whether they can continue to provide services. Only three states — California, Kentucky and Vermont — have instituted specific licensing guidelines  use of telehealth. Most states continue to follow policies devised long before technology allowed provider and client to interact from separate states.

Illinois licensing laws do not directly address telehealth counseling. All regular laws apply to telehealth.

  • Limited Federal Guidance on Coverage and Reimbursement: Despite Medicaid’s fewer restrictions on telehealth coverage as compared to its Medicare counterpart, there is limited federal guidance or information regarding the implementation of telehealth services in state Medicaid programs or coverage parameters for states choosing to offer such services. Health care practitioners who treat Medicaid populations are at risk for steep penalties for noncompliance, including fines and the potential loss of their professional licenses.
  • Lack of Meaningful Coverage by Third-Party Payors: A range of public and private payors do not provide meaningful coverage andreimbursement requirements for telehealth services.
    • A recent MedPAC survey noted that coverage of telehealth services continues to vary widely across commercial health plans, with most covering only one or two types of telehealth-based services.
    • According to MedPAC, most commercial health plans have had little incentive to offer telehealth services because there has been scant evidence of reduced costs or improved outcomes associated with telehealth services.

While telehealth parity laws are currently in effect in 39 states and the District of Columbia and are intended to ensure the same coverage of (and in some cases, reimbursement for) telehealth services, there is more work ahead to achieve comprehensive coverage and access. States must continue to enact new parity laws or expand existing ones. There are already plans for progress in 2019—for example:

  • Arizona will expand its existing parity law to include coverage of SUD treatment services provided through telehealth.
  • Kentucky legislation will go into effect on July 1, 2019, that requires commercial health plans to reimburse psychologists, therapists, and other non-physician providers for telehealth visits.
  • States including Alaska, Michigan, and Utah are amending their parity laws to expand or modify their applicability to additional specialties or types of providers.





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