The Centers for Medicare and Medicaid Services (CMS) provided a response to our letter. See here for the response from CMS.

The Alliance for Connected Care sent a letter to the Centers for Medicare and Medicaid Services (CMS) regarding the consideration of new telehealth codes as proposed by the American Medical Association (AMA) in 2023.

The AMA Relative Value Scale Update (RUC) Committee in May proposed 17-20 new telehealth codes to be considered in the CMS Medicare Telehealth Services List. The Alliance and its members oppose the creation of new telehealth codes that duplicate services already covered by the Medicare program for the following reasons: 

  1. Telehealth is a modality of care, not a different service. It is therefore inappropriate for CMS to adopt multiple codes for the same service.
  2. Telehealth has expanded access to care for underserved and rural populations. The complexity and potential payment variation created by duplicate codes would hinder CMS’s health equity priorities.
  3. The 17 new codes would leave out 200 services and outpatient codes which telehealth is currently used as a modality for.
  4. There could be significant patient access and operational impacts as the new codes are adopted.

Read the full letter here, or below.

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