Comment Letter on CY 2022 Physician Fee Schedule Proposed Rule
The Alliance for Connected Care submitted comments on the Medicare Physician Fee Schedule (PFS) Proposed Rule for calendar year (CY) 2022, which includes several important reforms with respect to telehealth. The Alliance applauds the proposal to retain all Category 3 telehealth codes through the end of Calendar Year (CY) 2023 to provide an opportunity to collect and study data on the telehealth experience during the COVID-19 public health emergency.
In advance of our more detailed response the Alliance emphasized the following overarching priorities:
- A great deal of confusion continues to exist around the authority of the Administration to make longer-term telehealth changes. We encourage CMS to continue clearly communicating to Congress and stakeholders that there are statutory limitations curtailing CMS’ 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 and its proposal to retain these codes through the end of the Calendar Year (CY) 2023, we continue to believe these codes are inadequate to the stability and predictability needed for health care providers to make necessary investments and plan for care/care systems in the longer term. Furthermore, and just as important, patients deserve and require predictability in their health care – and we urge CMS to consider patient expectations especially as patients have become more engaged in the delivery of health care services, and have become more ensconced in a hybrid model of health care delivery.
- While we recognize some statutory requirements exist, we remain very concerned with steps taken by CMS around in-person visit requirements. The Alliance and its members strongly believe that an in-person requirement constrains telehealth from helping individuals that are homebound, have transportation challenges, live in underserved areas, etc. It does not constrain those using telehealth for convenience. This creates a perversion of the Medicare payment system by reducing access for those who need it most, while allowing access for others.
- While we are supportive of CMS’ proposals to increase beneficiary participation and access in the Medicare Diabetes Prevention Program (MDPP) Expanded Model, we would like to highlight additional actions that would match CMS’ goals for the program. Specifically, the Alliance strongly feels that CMS should permit any CDC-recognized DPP suppliers to apply to become Medicare suppliers – including virtual DPP suppliers. Not only would permitting virtual suppliers to apply to become MDPP Expanded Model Suppliers increase the number of MDPP Suppliers participating in the program, but it would also broaden the reach of who can receive diabetes prevention services beyond brick-and-mortar locations, and provide convenient and timely access to a more diverse set of patients no longer burdened by needing to take time off everyday demands to complete the required curriculum.
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Open in new tab Summary: CY 2022 Proposed Physician Fee Schedule
On July 13, 2021, CMS released their proposed Calendar Year (CY) 2022 Medicare Physician Fee Schedule.Below is a summary of key payment and policy changes within the rule. Comments are due by September 13, 2021.
Physician Fee Schedule
Please find our summary of the PFS here.
Please find some topline elements and links below.
On July 13, 2021, CMS issued the proposed Calendar Year 2022 (CY2022) Physician Fee Schedule (PFS), which makes payment and policy changes under Medicare Part B.
CMS is proposing to retain all services added to the Medicare telehealth services list on a Category 3 basis until the end of CY 2023 – December 31, 2023 – to allow for time to collect more information regarding utilization of these services during the pandemic, and provide stakeholders the opportunity to continue to develop support for the permanent addition of appropriate services to the telehealth list through the regular consideration process, which includes notice-and-comment rulemaking.
In addition, CMS is proposing to amend the current regulatory requirement for interactive telecommunications systems to include audio-only communication technology when used for telehealth services for the diagnosis, evaluation, or treatment of mental health disorders furnished to established patients in their homes. CMS is proposing to limit the use of an audio-only interactive telecommunications system to mental health services furnished by practitioners who have the capability to furnish two-way, audio/video communications, but where the beneficiary is not capable of using, or does not consent to, the use of two-way, audio/video technology.
Finally, CMS is proposing to require an in-person visit be provided by the physician or practitioner furnishing mental health telehealth services within six months prior to the initial telehealth service, and at least once every six months thereafter.
- CMS is seeking comment on whether a different interval may be necessary or appropriate for mental health services furnished through audio-only communication technology.
- CMS is also seeking comment on how to address scenarios where a physician or practitioner of the same specialty/subspecialty in the same group may need to furnish a mental health service due to unavailability of the beneficiary’s regular practitioner.
CMS is also soliciting comment on: (1) whether additional documentation should be required in the patient’s medical record to support the clinical appropriateness of audio-only telehealth; (2) whether or not CMS should preclude audio-only telehealth for some high-level services, such as level 4 or 5 E/M visit codes or psychotherapy with crisis; and (3) any additional guardrails CMS should consider putting in place in order to minimize program integrity and patient safety concerns.
Please see our detailed summary of the proposed rule below:
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Back to School amidst the New Normal: Ongoing Effects of the Coronavirus Pandemic on Children’s Health and Well-Being
Kaiser Family Foundation: Back to School amidst the New Normal: Ongoing Effects of the Coronavirus Pandemic on Children’s Health and Well-Being
KFF published a new research brief examining how COVID-19 has affected the health and well-being of children. Among the key findings, children’s utilization of telemedicine services increased since the start of the pandemic, however, not enough to offset the decrease in service utilization overall, suggesting areas where children are still experiencing delays and barriers in accessing health care. Preliminary data suggest that telehealth utilization for Medicaid/CHIP beneficiaries under 19 increased rapidly in April 2020 and remains higher than before the pandemic. While telehealth utilization has increased, the increase has not offset the decreases in service utilization overall, and barriers to accessing health care via telehealth may remain, especially for low-income patients or patients in rural areas.
Utah Department of Health Center for Health Data and Informatics
Utah Department of Health Center for Health Data and Informatics:
A new literature review examines telehealth payment and makes conclusions whether legislation requiring payment parity should be considered. Key findings include:
- The costs of an ambulatory telehealth visit is on average around $40 lower compared to an in-person visit.
- Some telehealth services like ambulatory care take up lower physician time than in-person services, but some specialty telehealth services like surgery take up higher physician time.
- Physician professional organizations prefer payment parity for telehealth services.
- Patients and payers prefer the same level of telehealth services that were available and provided during the pandemic.
- In a study examining over 7 million private payer outpatient claims between 2010 and 2015, the investigators found that telehealth visits are 30% more likely to occur in states with at least some kind of coverage or payment parity laws compared to states with no telehealth parity laws during that time. The authors suggest that this is due to lack of reimbursement being a significant barrier to telehealth entry for many healthcare providers.
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Centers for Disease Control and Prevention – Household Pulse Survey
Centers for Disease Control and Prevention: Household Pulse Survey
According to the latest data from the latest data from the Census Bureau’s Household Pulse “near real-time” survey in partnership with HHS, telehealth usage dropped at the end of July and beginning of August, yet remains significantly above pre-pandemic levels.
Home Hospital increased in-patient capacity during the COVID-19 surge
EurekAlert! Home Hospital increased in-patient capacity during the COVID-19 surge
A research team from Brigham and Women’s Hospital has found that delivering acute care at home for non-COVID patients freed up substantial inpatient capacity during the COVID-19 surge last spring. From March 15, 2020, when Massachusetts’ state of emergency restrictions took effect, until the surge ended on June 18, 2020 (defined as less than 30 patients hospitalized with COVID-19), the Brigham’s Home Hospital program provided care for 65 acutely ill patients at home, amounting to 419 bed-days. Levine added that since the Centers for Medicare and Medicaid Services created a temporary payment mechanism for home hospital in November 2020, programs have rapidly grown across the U.S., with more than 145 hospitals taking up the model.
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Factors Associated With Use of and Satisfaction With Telehealth by Adults in Rural Virginia During the COVID-19 Pandemic
JAMA: Factors Associated With Use of and Satisfaction With Telehealth by Adults in Rural Virginia During the COVID-19 Pandemic
In a survey of nearly 300 participants in primarily rural Virginia counties found that roughly 80 percent were comfortable communicating with clinicians using telehealth, and 80 percent also said they would use telehealth again. Satisfaction among the 102 participants who used telehealth was associated with regular access to the internet and higher health literacy compared with those who were not satisfied.
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What does the future hold for telehealth? New report gives hints
University of Michigan Institute for Healthcare Policy & Innovation (IHPI): What does the future hold for telehealth? New report gives hints
A new report from the University of Michigan provides new data of disparities in adoption, access and attitudes when it comes to telehealth, through previously unreleased data as well as finding from published research.
Among the newly released findings:
- 1 in 5 patient visits covered by BCBSM as of March 2021 are by telehealth, showing the lasting interest in virtual visits even as the pandemic ebbed
- 91% of larger primary care practices in Michigan used telehealth, compared with 63% of solo practices. Larger practices also had a higher percentage of visits via telehealth.
- Striking disparities in use of video visits emerged from the analysis of Michigan Medicine data, with much lower use by patients who are older, are African-American, need an interpreter, have Medicaid as a primary insurance, or live in a zip code where less than half of households have broadband Internet access.
- Telephone-based audio-only visits have been covered by most insurers during the pandemic, but there are signs this may change once the emergency status is lifted. However, more than 60% of Michigan Medicine patients over age 65 used this option in May through June of 2020, with the percentage going up with age. Patients of any age who live in rural areas are also more likely to use audio-only visits.
- When all costs are taken into account, video visits and in-person visits cost approximately the same, and patients were no more likely to cancel or fail to show up for a video visit than they were for in-person visits.
- Half of all Michigan Medicine clinicians surveyed say that after the pandemic they intend to offer the same volume of video visits as now. About 40% said their productivity is the same now that telehealth is an option, and 27% say it’s higher. A majority said they were able to provide the same quality of care over telehealth and establish the same level of rapport with patients.
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New Survey: Virtual Care Could Keep Low-Acuity Cases Out of Emergency Department
Bipartisan Policy Center and Social Sciences Research Solutions (SSRS): New Survey: Virtual Care Could Keep Low-Acuity Cases Out of Emergency Department
The Bipartisan Policy Center (BPC) released findings from a national survey conducted by the Social Sciences Research Solutions (SSRS) on the uses of telehealth during the pandemic, along with its effectiveness and challenges. SSRS spoke with 1,776 adults, including an oversample of older adults, Hispanic and Black adults, as well as rural residents. The survey was conducted through landline and cellphone calls between June 28, 2021–July 18, 2021. The goal of the survey was to gain a better understanding of the quality and effectiveness of telehealth services, and the barriers consumers faced over the past year.
- The survey found that access to telehealth kept people out of the emergency department during the pandemic. About one in seven people (14%) who used telehealth said they would have sought care in an emergency department or urgent care if telehealth was not available, and more than half of those people had their primary health issue resolved.
- Notably, older adults were almost twice as likely to have had a telehealth visit in the past year compared to those under 30; and Medicare beneficiaries had the highest rates of telehealth use at 44 percent.
- The most common purpose for a telehealth visit was a preventive service, prescription refill, or routine visit for a chronic illness (63%). Rural residents said they were more likely to use telehealth for surgical consults than people living in non-rural areas.
- Nearly all (94%) respondents said they were satisfied with the quality of care in their telehealth visit; including 95 percent of Medicare beneficiaries. In addition, adults who had an audio-only visit had similar levels of satisfaction and issue resolution as those with a video visit.
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State Of Telehealth Q2’21 Report: Investment & Sector Trends To Watch
CB Insights – State of Telehealth Q2`21 Report: Investment & Sector Trends to Watch
Global telehealth investment rose for the fourth consecutive quarter, growing 17% quarter-over-quarter and 169% year-over-year to reach a record high of $5B across 163 deals. The investments are more than double what they were in the second quarter of 2020. While all telehealth segments saw acquisitions during the quarter, the 2 biggest hot spots were virtual/digital care enablement and telemedicine providers, platforms, & marketplaces. Read additional coverage from Healthcare Dive.
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