Alliance CY 2025 Medicare Physician Fee Schedule Comments

The Alliance for Connected Care provided comments to the calendar year (CY) 2025 Medicare Physician Fee Schedule (PFS) proposed rule.

As reflected in the comments below, the Alliance appreciates CMS for ensuring certainty to telehealth access to Medicare beneficiaries to the extent it could. The Alliance is committed to leveraging telehealth and remote patient monitoring to improve quality of care while also lowering costs and improving the clinician experience.

The Alliance would like to emphasize the following overarching priorities in advance of our more detailed response:

The Alliance supports the CMS proposal for a one-year extension to provide time to address provider enrollment and billing concerns related to the provision of telehealth services form a provider’s home or non-clinical location. The Alliance seeks clarification on specific requirements related to enrollment and billing of these providers.
The Alliance strongly supports the continued availability of direct supervision through telehealth for both the treatment of patients and the training of residents. We urge CMS to consider additional clinical situations in which virtual direct supervision is also acceptable. We applaud CMS for permanently allowing virtual direct supervision for lower acuity health care services provided incident to a physician.
The Alliance applauds the CMS decision not to cover duplicative codes for telehealth services. We believe that the adoption of these codes would undermine the broader efforts of the Administration to ensure equitable access to the full spectrum of Medicare services.
While reimbursement is a concern for many services, the Alliance is most concerned with the dramatic and continuing decline in reimbursement for remote patient monitoring. We believe that this decline presents a significant barrier for most Medicare beneficiaries to receive services that both CMS and the Alliance believe are valuable for patients with chronic conditions.
The Alliance strongly supports permanent CMS action to protect and ensure access to audio-only telehealth when clinically appropriate and needed by the patient.