Alliance for Connected Care Calls on CMS to Modernize Telehealth Policy and Expand Access to Virtual Care

The Alliance for Connected Care submitted a letter to CMS urging additional regulatory changes to digital health rules in the Physician Fee Schedule, ensuring patients and providers alike have access to health care where and when they need it. In our advocacy for a more connected health care system, the Alliance calls on CMS to:

Ensure the new statutory telehealth modifiers do not create burdensome requirements, clearly define the term “virtual platform”, and establish a clear exemption list within its definition of clinicians offering care through a “virtual platform.”
Ensure that telehealth practitioners working solely from a home-based location do not need to report their private residence to the federal government for purposes of enrollment or billing. We respectfully request that CMS, as part of its policymaking in this area, convene a roundtable or a similar effort to ensure the experiences of virtual-only practitioners are considered.
Recognize AI-enabled care as an extension of existing medical services and align reimbursement with clinical outcomes and medical decision-making rather than rigid time-based requirements. One way would be through enablement of innovative “regulatory sandboxes” that create AI regulatory relief pathways that allow for temporary exemptions from regulation, subject to rigorous due diligence, safety constraints, and narrowly scoped use cases at the state and federal level.
Build on recent progress supporting remote patient monitoring (RPM) by modernizing practice expense valuation for digital tools, expanding clinical use cases, and supporting technology investments that improve chronic disease management.
Provide greater flexibility for teaching physicians to bill based on how they interact with the patient and the key and critical elements they personally perform and should provide location flexibility for clinical teams.
Modernize interprofessional consultations by removing outdated time thresholds and supporting secure digital collaboration among clinicians to improve care coordination.
Advance outcome-oriented care models such as APCM and ACCESS that reward longitudinal care management, technology-enabled services, and measurable improvements in patient outcomes.
Create an additional billing pathway, such as incident-to billing, in Medicare Diabetes Prevention Program (MDPP) to allow primary care providers to oversee delivery of MDPP services furnished by CDC-recognized suppliers.
Promote interstate care and reduce licensure barriers that limit providers’ ability to deliver telehealth services across state lines and exacerbate workforce shortages.
Continue working with Congress to ensure permanent Medicare telehealth access, including maintaining coverage for audio-only services and ensuring a broad range of clinicians can deliver virtual care.