According to a survey conducted by the National Business Group on Health, 96 percent of large employers are either making or planning to make telemedicine available to their employees. Considering the time and cost savings for patients, insurance companies, and employers, this sounds like it could be a panacea. However, the logistics of implementing telemedicine benefits for employees are far from simple. An employer, whether insured or self-funded, who wants to provide telemedicine services can do so in one of three ways: integrate telemedicine as part of a group health plan, bundle telemedicine services as part of an Employee Assistance Program (EAP), or offer telemedicine services separately as a stand-alone benefit. Each method carries varying degrees of compliance issues with state and federal laws such as ERISA.
This article is part one of a two-part series exploring the methods employers can use to offer telemedicine benefits to their employees. Click here for part two.
Add-on to Group Health Plan
The easiest route, from the employer’s perspective, is to attach the telemedicine service to an existing group health plan. In this case, the new service is not subject to separate documentation and filing requirements because it comprises only one portion of a larger package; the group health plan, as a whole, must fulfill the legal requirements—not the employer. The group health plan is also responsible for overseeing the telemedicine service’s HIPAA privacy and security processes.
One caveat, however, is that employers must make sure they do not violate the requirements of the Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA); while the group health plan must follow this law, telemedicine vendors are not held to this standard. Ultimately, the employer is responsible for compliance and thus should monitor both the group health plan and telemedicine service provider. In addition, the employer must make sure that any staff members who use a Health Savings Account (HSA) and who are enrolled in a high deductible health plan (HDHP) do not have any “disqualifying coverage” that could damage their HSA eligibility.
Despite the relative ease of this approach, it inherently carries one major flaw: The telemedicine benefit is limited to only those employees who participate in the employer’s health plan. Employees who obtain medical insurance elsewhere or who are ineligible for the employer’s medical plan are left out completely.
Overall, adding a telemedicine service to an existing group health plan seems to be a convenient and cost-effective method for employers who want to roll out telemedicine benefits for employees quickly. The biggest downside is that not every employee will have access; but no one is perfect, right?
Next week, we’ll discuss the remaining two ways that an employer can offer new telemedicine benefits for employees.