If you didn’t already know it, your iPhone likely has a health app that was added as part of a software update. Recently Apple announced that it will be using its latest iPhone software update to allow users to register as organ donors. Technology is changing the way we store and provide our medical information. In just the same way, technology is transforming how we access and receive health care through the use of telemedicine. But with this transformation, questions on the quality of care, reimbursement under insurance, and the general practice of medicine continue to arise. Answers are not always clear and likely vary depending on where you live.

In particular, the question of how telemedicine can be used to fill in network adequacy gaps, particularly as states put insurer networks under closer scrutiny remains to be answered. As we noted in a recent brief about telemedicine’s potential impact on network adequacy, states have been slow to provide guidance on how and when insurers can use telemedicine providers to meet network adequacy standards. In our study of six states – Arkansas, Colorado, Illinois, Maine, Texas, and Washington – regulators had not publically provided clear guidance to insurers on the appropriate use of telemedicine to meet network adequacy standards.

At the same time, however, more and more states are requiring coverage parity for health care services provided through telemedicine or lifting restrictions on telemedicine reimbursement. For example, Colorado recently lifted its reimbursement restriction, which only allowed for telemedicine reimbursement to areas with 150,000 or less residents, beginning January 1, 2017. And as we found in our report, Colorado was the only study state to explicitly allow insurers to use telemedicine providers to meet that state’s network adequacy standard for specialty providers. Colorado also issued a bulletin reiterating this position.

As telemedicine continues to transform how we access care, states will be pushed to change their approaches to regulatory oversight as well, particularly with network adequacy. While most states appear to be silent on how telemedicine can be used for network adequacy purposes, the time for action may come sooner than later as more consumers, providers, and insurers embrace the use of telemedicine.