Pre-Existing Workforce Trends Account for a Large Share of Projected Medicaid Telehealth Growth
Comparing multi-year provider trends with modeled post-policy jumps across Medicaid claims.
County and state Medi-Cal teams track monthly billing providers to judge whether telehealth pay rules expanded care access. However, clinic staffing and provider billing counts were already growing each year before 2020. Comparing one pre-policy year with one post-policy year blends that ongoing trend into the policy review.
When auditing a telehealth rollout by comparing billing providers in 2019 against 2023, a modeled two-point check overstates the policy jump by mixing new pay rules with workforce growth that was already underway.[1] Across 84 months of Medicaid claims (2018 to 2024), monthly billing providers for telehealth-eligible services grew from 91,399 in 2019 to 113,638 in 2023 (+22,239 providers, or +24.33%), but that list was already adding 6,977 billers per year (+8.26%) before 2020.[1][2] Checking multi-year base slopes next to other care (+18.71%) keeps budget teams from over-funding routine trend growth.[2][3]
Table 1. Medicaid Billing Providers Across 4 Study Windows
Yearly means of monthly billing providers from HHS Medicaid claims (2018 to 2024) with modeled base-trend paths.
| Trend Measure |
Window 1: Base
Pre-2020 Pace (2018-2019)
|
Window 2: Peak
2019 to 2023 Rollout
|
Window 3: Full
2019 to 2024 Span
|
Comparison Line
Other Medicaid Care
|
|---|---|---|---|---|
| Monthly Billing Providers | 84,422 -> 91,399 | 91,399 -> 113,638 | 91,399 -> 101,978 | 101,905 -> 116,690 |
| Two-Point Provider Change | +6,977+8.26% | +22,239+24.33% | +10,579+11.57% | +14,785+14.51% |
| Mean Gain per Year | +6,977 / yr | +5,560 / yr | +2,116 / yr | +2,464 / yr |
| Straight-Line End Value* | Base sloperef | 119,3072023 | 126,2842024 | 144,9972024 |
| Net Gap vs. Pre-2020 Trend* | 0 (base ref) | -5,669-4.75% | -24,306-19.25% | -28,307-19.52% |
| Compound-Rate Gap* | Base rateref | 125,549 vs. 113,638-11,911 | 135,919 vs. 101,978-33,941 | 153,358 vs. 116,690-36,668 |
| Total Medicaid Paid | $19.23B -> $23.56B | $23.56B -> $40.29B | $23.56B -> $34.93B | $85.47B -> $145.72B |
| Billing Codes per Month | 171.0 -> 191.0 | 191.0 -> 222.7 | 191.0 -> 220.7 | 4,424.2 -> 4,518.2 |
Table 1 Notes & * Modeled Estimates
Expand notes
Table 1 Notes & * Modeled Estimates. Counts come from the HHS Medicaid Provider Spending file (84 months, Jan 2018 to Dec 2024). Mode A rows extend the 2018 to 2019 base pace (+6,977 per year or +8.26% per year) through 2023 and 2024.
Column Scope. Pre-2020 Pace (2018-2019). Video Care, 2018 to 2019. 2019 to 2023 Rollout. Video Care, 2019 to 2023. 2019 to 2024 Span. Video Care, 2019 to 2024. Other Medicaid Care. Non-Video Care, 2018 to 2024.
Two-Ruler Benchmark Summary. Mode A Base-Trend Paths on HHS Medicaid Provider Spending (84 Months, Jan 2018 to Dec 2024). Ruler 1: Raw Two-Point Change (2019 to 2023): +22,239 Providers (+24.33%). Mean monthly billing providers rose from 91,399 in 2019 to 113,638 in 2023. A two-point check assigns all +22,239 new billers to post-2019 rules. Yet the count was already rising from 84,422 in 2018. Measured through 2024, the raw gain shrinks to +10,579 (+11.57%) after a -11,660 (-10.26%) drop in 2024. Ruler 2: Mode A Base-Trend Gap: -5,669 vs. Base Path (2023). The straight-line path extends the 2018 to 2019 pace: 91,399 + 4 × 6,977 = 119,307 in 2023. The actual count of 113,638 sits 5,669 below that line (-4.75%). By 2024 the gap reaches -24,306 (126,284 projected vs. 101,978 actual). A compound +8.26% annual rate gives -11,911 in 2023. Both paths show how much the result rests on the chosen base trend.
Method & Data Audit (TooEarlyToSay.com): Medicaid Provider Spending File Guide → · Medicaid Billing Feature Construction Guide →
Table 2. Base Trends, Budget Tradeoffs & Policy Fit
How checking pre-2020 slopes and other Medicaid care guides budget review.
| Choice Factor | Pre-2020 Pace (2018-2019) | 2019 to 2023 Rollout | 2019 to 2024 Span | Other Medicaid Care |
|---|---|---|---|---|
| Observed Path in Window | Monthly billers rose from 84,422 in 2018 to 91,399 in 2019 (+8.26%) before 2020. | Counts hit 113,638 in 2023, yet the yearly gain stayed below the 2019 pace. | The 2024 mean fell to 101,978 (-10.26%) while late-2024 claims were still pending. | Other care rose from 101,905 in 2018 to 129,492 in 2023 and 116,690 in 2024. |
| What Base Trends Show | Sets the base slope at +6,977 billers per year or +8.26% per year. | The +22,239 raw gain sits 5,669 below the straight-line path of 119,307. | The +10,579 gain sits 24,306 below the line as redetermination and claim lags mix. | Other care grew +18.71% through 2023, matching 77% of the +24.33% video care gain. |
| Budget Tradeoff | One base year sets every later line, so shifting the start year moves the gap. | Crediting all +24.33% to new rules funds growth that tracks the pre-2020 slope. | Reading the -10.26% drop in 2024 as a real loss risks cutting funds before claims clear. | Budget teams can weigh the 6.29-point gap over other care instead of the raw gain. |
| Next Step to Check | Add Earlier Base Years. Include pre-2018 months and test more than one base window before scoring pay rules. | Pair With Other Care. Compare the +24.33% gain against other care (+18.71%) before crediting policy. | Wait for Full Claims. Refresh Nov and Dec 2024 after claims clear to see if the 2024 dip lasts. | Track as Base Benchmark. Follow other care each month since it shares enrollment shifts without video pay rules. |
Table 2 Notes: Series Scope, Base-Trend Math & Claim Lags
Expand notes
• Data Source (Observed Series): Monthly counts (telehealth_month_summary.parquet, 168 rows = 84 months × 2 care groups, Jan 2018 to Dec 2024) come from the HHS Medicaid Provider Spending file. Each month tracks billing providers, code counts, claims, paid dollars, and members. Yearly provider and code figures are 12-month means. Paid dollars and claims are 12-month sums.
• Mode A Base-Trend Paths: Straight-line path: path(year) = 91,399 + (year − 2019) × 6,977. For 2023, 119,307 vs. 113,638 actual = −5,669. For 2024, 126,284 vs. 101,978 = −24,306. Compound path: path(year) = 91,399 × 1.0826^(year − 2019). That yields 125,549 (−11,911) in 2023 and 135,919 (−33,941) in 2024. Other care uses its own 2018 to 2019 change (+7,182, +7.05%). Both paths are Mode A checks.
• Late-2024 Claim Lags: In the HHS Medicaid Provider Spending series, billing providers drop to 88,364 in Nov 2024 and 47,562 in Dec 2024. Jan to Oct 2024 ranged from 101,691 to 119,937 (mean 108,781, +19.02% vs. 2019). Other care shows the same late-2024 dip (101,476 and 57,878). The 2024 full-year mean therefore mixes Medicaid redetermination with unpaid late-year claims.
How Multi-Year Trends Improve on Two-Point Checks
Yearly program reviews that compare one pre-policy year against the latest year mix prior workforce growth with the policy change. A simple two-point gap cannot tell whether a rule caused a jump. A multi-year trend may have kept climbing on its old slope, or a broad enrollment wave may have lifted every service line at once.
Checking the full 2018 to 2024 series sharpens budget review. Billing providers for video care were already growing +8.26% per year before 2020. Other Medicaid care grew +18.71% from 2019 to 2023 next to the +24.33% video care gain. A straight-line path from 2018 to 2019 leaves 2023 at 5,669 providers below trend, and the compound path leaves it 11,911 below. Multi-year base trends thus work best as a check on two-point claims.
Data Sources, Model Inputs, Notes & Endnotes
(Numbered endnotes [1]–[5], state data sources & math rules)
Expand details
Case Study Focus: Program Impact · Pre-Post Study & Base Trends (Mode A on HHS Medicaid Provider Spending)
Numbered Endnotes & Main Sources
- [1]Observed Medicaid Billing Series (2018-2024): U.S. HHS Medicaid Provider Spending File monthly counts (84 months, Jan 2018 to Dec 2024). Mean monthly billing providers for telehealth-eligible care rose from 84,422 in 2018 and 91,399 in 2019 to 113,638 in 2023 and 101,978 in 2024.
- [2]Base Pre-Trend Path: Billing providers grew +6,977 per year (+8.26%) from 2018 to 2019. Extending that straight line projects 119,307 providers in 2023 (-5,669 vs. actual) and 126,284 in 2024 (-24,306 vs. actual).
- [3]Other Care Series & Policy Rules: Other Medicaid care (101,905 in 2018, 109,087 in 2019, 129,492 in 2023, +18.71% growth from 2019 to 2023) and California DHCS Telehealth Policy Guidance.
- [4]Medicaid.gov Open Data
- [5]CMS T-MSIS Analytic Files Documentation
Mode Classification (Mode A on Observed Series): Billing provider counts, code counts, claims, paid dollars, and member-months come from the HHS Medicaid Provider Spending file (telehealth_month_summary.parquet, Jan 2018 to Dec 2024). The unit of analysis is care-group-month (2 groups × 84 months = 168 rows). The straight-line and compound paths are Mode A trend checks on these observed series.
Primary Data Sources: U.S. HHS Medicaid Provider Spending File, Medicaid.gov Open Data, CMS T-MSIS Analytic Files Documentation, and California DHCS Telehealth Policy Guidance.
Companion Method & Code Guides (TooEarlyToSay.com)
- What 238 Million Medicaid Billing Rows Can Support. Row grain, seven fields, and suppression rules of the HHS Medicaid provider-spending file (238,015,729 aggregated billing rows), and the clinical context a screening decision still requires.
- What Billing Patterns Actually Look Like. Provider-level billing features built from 84 months of aggregated billing rows; the excluded-provider billing comparisons are under reconciliation.
Common Questions & Method Notes
- What is a raw pre-post check in health program review?
- A raw pre-post check subtracts one pre-policy year from one post-policy year. It credits the whole gap to the new rule and leaves out ongoing base trends and broad system shifts.
- How does the Medicaid series show the limits of a two-point check?
- Monthly billing providers for telehealth-eligible care rose 22,239 (+24.33%) from 2019 to 2023. Yet the count had already grown 6,977 (+8.26%) from 2018 to 2019. Other Medicaid care also rose 18.71% from 2019 to 2023.
- What is the first data check to run before using a pre-post number?
- Plot at least 12 to 24 months of pre-policy data to see if the count was already rising or falling. Then compare that path against a service line that did not get the policy change.