How Emerging Telehealth Models Challenge Policymaking

Health Care Practice / Quality

Policy Points:

  • Current telehealth policy discussions are focused on synchronous video and audio telehealth visits delivered by traditional providers and have neglected the growing number of alternative telehealth offerings.
  • These alternative telehealth offerings range from simply supporting traditional brick-and-mortar providers to telehealth-only companies that directly compete with them.
  • We describe policy challenges across this range of alternative telehealth offerings in terms of using the appropriate paymentmodel, determining the payment amount, and ensuring the quality of care.

For years, telehealth has been touted as a potentially transformative technology that will increase health care access and efficiency. Although the use of telehealth already was growing, the pandemic drove a dramatic expansion.1,2 Many of the temporary telehealth waivers established during the pandemic to spur this growth are set to expire at the end of the public health emergency. This has resulted in intense interest in permanent changes in telehealth policy across state legislatures and Congress.3–5 The most common forms of telehealth—video visits and, to a lesser extent, audio-only visits delivered by traditional “brick-and-mortar” providers—are the focus of most of the debate.6–9 Key components of debate include the types of visits that should be covered, whether there should be payment parity for telehealth and in-person visits, and whether physicians’ licensure should extend across state lines.

These ongoing debates do not, however, capture the full breadth of telehealth offerings available today and in the near future. Accordingly, we are concerned that any payment and regulatory policies implemented may soon be out of date. An example is Ginger, a telehealth offering that provides members unlimited 24/7 access to behavioral health coaches through text communication in its app, with escalation as needed to virtual therapy sessions with licensed therapists and psychiatrists.10 Ginger has partnerships with hundreds of employers and recently became an in-network care option for 14 million Cigna members.11 With its fully virtual caremodel, Ginger has much lower overhead costs than a traditional brick-and-mortar practice. How, then, should payment rates reflect these lower operational costs? Ginger uses unlicensed health coaches,12 so how should states ensure quality, given that current licensure-based mechanisms do not apply? Ginger typically charges a monthly fee per patient,13,14 but such paymentmodels are not reflected in current discussions about payment. Moreover, Ginger is only one of many alternative telehealth products, which are themselves highly heterogeneous, reflecting not only differences in target conditions but also distinct approaches to delivering care.

In this perspective, we first describe the wide array of emerging alternative telehealth offerings and then discuss how these newer models may impact payment policies and regulations. We hope that by raising these issues, we can inform a more holistic telehealth policy strategy.



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  10. The Ginger Experience. experience. Accessed September 11, 2021.
  11. Barnes V. Ginger brings on-demand mental healthcare to 14 million Cigna behavioral health customers nationwide. Business wire. Ginger-Brings-On-Demand-Mental-Healthcare-to-14-Million- Cigna-Behavioral-Health-Customers-Nationwide. Published April 28, 2021. Accessed September 11, 2021.
  12. Ginger US: Medical p.c. terms of service. https:// Published April 1, 2021. Accessed September 11, 2021.
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  14. Ginger FAQ. Accessed September 11, 2021.


M. Tang, M.E. Chernew, A. Mehrotra. How Emerging Telehealth Models Challenge Policymaking. Milbank Q. September 28, 2022.