The American Telemedicine Association was among several groups this week that submitted comments to the Centers for Medicare and Medicaid Services regarding the 2021 Physician Fee Schedule proposed rule.
The comments focused on three areas: expanding access to more telehealth services and providers, changes to remote patient monitoring services, and telehealth in federally qualified health centers and rural health clinics.
“The ATA strongly supports increased access to telehealth services in the Medicare program to increase access to clinically and cost-effective care, particularly for our most vulnerable populations,” said ATA CEO Ann Mond Johnson in a statement.
WHY IT MATTERS
Expanding telehealth services and providers has been generally supported across the political spectrum, and the ATA’s comments are no exception.
The proposed CMS rules would make permanent additions to the telehealth services list nine codes that were temporarily covered during the COVID-19 public health emergency. Among other changes, the ATA supports adding these codes for group psychotherapy, neurobehavioral status exam, and evaluation and management.
The ATA also supports reimbursement of audio-only services when clinically appropriate – which advocates have noted is vital for those who may not have access to broadband or technology.
“During the COVID-19 pandemic, we encourage CMS to cover audio-only services more widely to ensure patients can maintain critical access to care in a time of social distancing,” wrote ATA officials in their recommendations.
The group also noted that some of CMS’ attempts to clarify questions around remote patient monitoring may serve to instead disrupt current clinical practices. It argued that the proposed billing rules may be severely limiting for patients who use multiple devices for chronic conditions, such as patients with Type 2 diabetes who may need a glucometer and a weight scale.
“While perhaps well-intentioned, CMS proposes new changes to remote patient monitoring codes that are not consistent with current practice,” said Mond Johnson. “The ATA looks forward to working with the agency to solve these issues and ensure that this type of remote care is available to patients.”
The ATA also pointed out that federally qualified health centers and rural health centers are not listed in statute as telehealth providers for Medicare telehealth services, and it supported permanently including them as such – and reimbursing them accordingly.
“The ATA is working with Congress to add FQHCs and RHCs to statute and to ensure a fair permanent payment system, which is not currently reflected by the temporary payment created for the pandemic,” said the ATA in the recommendations.
THE LARGER TREND
Telehealth reimbursement after the public health emergency has been a continued cause for debate, with groups offering a variety of potential solutions. MedPAC, for example, earlier this month raised the idea of reimbursing differently for some providers based on their participation in alternative payment models.
Primary care providers in particular have pointed to the uncertainty around coverage as a hurdle, with Mathematica Senior Fellow Dr. Diane Rittenhouse telling Healthcare IT News that some clinicians were seeing patients at the start of the pandemic “essentially for free.”
“It’s really an issue of not being able to survive if they’re delivering care for free. If they don’t get paid for it, if they don’t get reimbursed for it, then how do they function?” said Rittenhouse.
ON THE RECORD
“Telehealth will be particularly effective in value-based care arrangements as it can produce better outcomes at lower cost,” said Mond Johnson in a statement about the fee schedule. “The ATA appreciates CMS’ efforts to expand access to telemedicine.”