The Alliance submitted comments on the CY 2021 Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment Policies.
The Alliance emphasized four overarching priorities:
- We encourage CMS to continue clearly communicating to Congress and stakeholders that there are statutory limitations curtailing CMS’s ability to allow continued access to telehealth for Medicare beneficiaries. Additionally, we urge you to continue collecting and publicly sharing data about telehealth utilization and inform a conversation with Congress around what statutory authorities CMS needs to make thoughtful, long-term policy.
- While we appreciate and support CMS’s effort to create temporary category 3 codes, we do not believe these codes create the adequate stability and predictability needed for healthcare providers to make necessary investments and plan for care/care systems in the longer team. CMS should be making additional permanent changes within its authority, even if those changes may require revision at a future date. CMS should also aggressively leverage a much wider set of category 3 codes to help create a smoother, calendar year-aligned, “off-ramp” for those services which may not continue – rather than having an abrupt and unpredictable ending with the close of the public health emergency.
- We are particularly concerned with steps taken by CMS around remote patient monitoring. Specifically, the Alliance does not agree with CMS’s interpretation of codes 99457 and 99458 and the proposed requirement that “interactive communication” consist of real-time synchronous two-way audio. Requiring real-time interaction is inconsistent with the opportunity and intent of remote patient monitoring technologies, which are effectively delivered using a mix of both synchronous and asynchronous modalities.
- While we strongly support a system-wide telehealth expansion, we note that there is no reason for CMS not to immediately leverage its full authority to permanently expand the use of telehealth flexibility within outcome-based alternative payment models. The concerns about long-term expansion expressed by CMS and others do not exist in models with aligned incentives and accountability for quality, cost, and patient satisfaction.
We also recognize there are statutory restrictions that limit the ability of CMS to permanently extend several longstanding and antiquated telehealth issues. We encourage CMS to explore opportunities and coordinate with Congress to expand the types of practitioners who may furnish and bill Medicare telehealth services, including for physical therapy, occupational therapy, and speech-language pathology services, which have proven both effective and necessary during the PHE.
View our full comments below: