Alliance Highlights the Importance of a Special Registration to Allow Continuity of Care for Patients
The Alliance for Connected Care appreciated the opportunity to testify for the Drug Enforcement Administration’s (DEA) listening session on prescribing controlled substances via telemedicine on September 12, 2023.
We appreciate the DEA’s quick response during the COVID-19 public health emergency (PHE) to allow prescribing via telemedicine. This was also a hugely meaningful expansion of access for Americans who had other barriers to accessing care. These include individuals who are frail, homebound or lack transportation, who live in areas with provider shortages, people of all kinds whose caregiving responsibilities serve as a barrier to care. We strongly support the development and implementation of a permanent policy for the prescribing of controlled substances though telemedicine to ensure these individuals do not lose access – as these are not challenges which will go away.
In our testimony, the Alliance discussed the importance of a special registration as the primary guardrail to identify and mitigate the risks of diversion in the prescribing of controlled substances through telehealth, and discuss implementation concerns for any proposed regulation.
Read the full testimony here.
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Comment Letter on CY 2024 Physician Fee Schedule Proposed Rule
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The Alliance for Connected Care submitted comments on the Medicare Physician Fee Schedule (PFS) Proposed Rule for calendar year (CY) 2024, which includes several important reforms with respect to telehealth.
The Alliance emphasized the following overarching priorities:
- The Alliance appreciates and supports the proposal from CMS to pay claims billed with POS 10 (Telehealth Provided in Patient’s Home) at the non-facility PFS rate. We applaud CMS for this choice, which recognizes that Medicare services provided via telehealth are simply a different modality for patients to receive the same care. However, rather than defining this payment rate around POS 10, we recommend that CMS consider instead offering the non-facility payment rate to any non-facility telehealth service.
- 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 make expanded direct supervision through telehealth permanent. The option for virtual direct supervision is needed to strengthen our health system’s capability to meet longstanding health care challenges through increased access and a more flexible workforce.
- We appreciate CMS efforts to expand access to remote monitoring for Medicare patients served by Rural Health Clinics (RHCs) and Federally Qualified Health Care Centers (FQHCs), but believe that the use of code G0511 as proposed will fail to expand access or improve health equity due to restrictions on how the code can be billed and the reimbursement rate which is far lower than equivalent services when offered by other providers.
- We are optimistic for the revised review process for the Medicare Telehealth Services List but have some concerns with how this process is described – specifically around the thresholds for a code to be considered on a provisional status. We applaud CMS for attempting to provide more transparency in its process, and look forward to working with you to strengthen the process through which we evaluate which services are appropriate for delivery through telehealth.
Please find the full comments below or here.
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Alliance Support Letter for DC Bill 25-125 – Uniform Telehealth Act of 2023
The Alliance submitted a letter of support to Christina Henderson, Chair of the Committee on Health within the Council of the District of Columbia, for Bill 25-125 – Uniform Telehealth Act of 2023.
The bill would adopt the Uniform Telehealth Act in the District of Columbia, which would provide the District with the clear guidance and framework needed to facilitate the delivery of services via telehealth consistent with the standard of care of the jurisdiction in which the patient is located. It would also establish a registration system for out-of-state practitioners to provide telehealth services to patients located in the jurisdiction adopting this Act, therefore enabling practitioners to provide widespread assistance to patients in a more convenient and cost-effective manner.
This bill would be a foundational first step to better facilitate the delivery of telehealth services and address the patchwork of licensure laws that exist from state to state to ensure patients can continue to be at the center of their care.
Read the full letter here and below:
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Alliance Leads More than 185 Organizations in a Letter Supporting the Telehealth Expansion Act
The Alliance for Connected Care led 188 organizations in a letter urging House Ways & Means Committee leaders to advance the Telehealth Expansion Act of 2023 (H.R. 1843/S. 1001) to the full House of Representatives for consideration.
The Telehealth Expansion Act of 2023 is a bipartisan, bicameral bill that would make permanent the pandemic-era policy that enabled employers to provide telehealth services on a pre-deductible basis to individuals with high-deductible health plans coupled with a health savings account (HDHP-HSA). The bill would ensure this critical telehealth flexibility continues for the more than 32 million Americans with these plans on a permanent basis beyond the current extension through December 31, 2024. This commonsense policy has helped ensure families could access vital telehealth services – including virtual primary care and behavioral health services – prior to having to meet their deductible. In fact, according to a survey by the Employee Benefit Research Institute (EBRI), about 96 percent of employers adopted pre-deductible coverage for telehealth services as a result of this pandemic-era provision.
The letter supported a successful effort in advocating for the favorable reporting of this bill out of the House Ways & Means Committee during a markup of the bill on June 7, 2023. See the Alliance statement here.
For more information and the Alliance’s advocacy on this policy, please click here.
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Statement on the Telehealth Expansion Act of 2023
The Alliance for Connected Care is pleased to support the Telehealth Expansion Act of 2023 (H.R. 1843/S. 1001) and applauds Representatives Steel (R-CA), Lee (D-NV), Smith (R-NE), and Schneider (D-IL) and Senators Daines (R-MT) and Cortez Masto (D-NV) for their leadership in introducing this bipartisan, bicameral legislation.
This bill would make permanent the CARES Act authority allowing employers and health plans to cover telehealth visits for individuals with high-deductible health plans coupled with a health savings account (HDHP-HSA) before having to meet their deductible. This flexibility has been critical to ensuring American families could maintain access to a range of affordable virtual care services on a pre-deductible basis throughout the COVID-19 pandemic, and is currently extended through December 31, 2024 as a result of the Consolidated Appropriations Act, 2023.
There are more than 32 million Americans with HDHP-HSAs. More than 50 percent of individuals with an HSA live in zip codes where the median income is below $75,000 annually. Reaching the deductible threshold of $1,400 for an individual and $2,800 for a family is often a financial strain. Allowing employers to offer pre-deductible coverage of telehealth services for employees with HDHP-HSAs provides meaningful access to health care services before the deductible is met.
These policies are also popular among patients and plan sponsors in the commercial market. For example, a 2021 survey of health plans found that the top services most likely to improve patient satisfaction if covered pre-deductible for individuals with an HDHP-HSA were primary care visits (81 percent) and the permanent ability to offer telehealth services (64 percent).
“Millions of Americans spend thousands of dollars of their own money on medical services before their insurance kicks in. Even with the benefit of tax exclusion, high deductibles are a struggle for many individuals and families. Why wouldn’t we want to allow employers to cover telehealth, including primary care and mental health services, immediately regardless of deductible? It’s access to health care, plain and simple,” said Krista Drobac, Executive Director of the Alliance for Connected Care. “The Alliance for Connected Care is proud to support the Telehealth Expansion Act, which will ensure individuals with HDHP-HSAs continue to have ready access to virtual-care services on a permanent basis.”
The Alliance was please to lead a stakeholder letter in support of this bill, which had more than 185 organizations sign on in support. The letter supported a successful effort in advocating for the favorable reporting of this bill out of the House Ways & Means Committee during a markup of the bill on June 7, 2023.
For more information and the Alliance’s advocacy on this policy, please click here.
The Telemedicine Experience in Primary Care Practices in the United States
Annals of Family Medicine: The Telemedicine Experience in Primary Care Practices in the United States
The need to rapidly implement telemedicine in primary care during the COVID-19 pandemic was addressed differently by various practices. Using qualitative data from semi-structured interviews with primary care practice leaders, the researchers of this study identified four overarching themes, including a need for more explicit telehealth visit triage guidelines following the COVID-19 public health emergency. The study adds to research surrounding telehealth use within the primary care arena in the US.
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Digital Tools in Cancer Care
Association of Community Cancer Centers: Digital Tools in Cancer Care
The Association of Community Cancer Centers conducted a survey, which found that providers, patients, and caregivers were willing to utilize digital, remote patient-monitoring (RPM) tools to report symptoms throughout anti-cancer treatments. Key survey results found more than half (60 percent) of providers who implemented an RPM program said it added “10 hours or less” to a weekly workload. Of the 60 percent, almost half (40 percent) said the program did not “significantly disrupt workflow,” with 24 percent noting the technology actually improved workflow.
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Overall and Telehealth Addiction Treatment Utilization by Age, Race, Ethnicity, and Socioeconomic Status in California After COVID-19 Policy Changes
JAMA Health Forum: Overall and Telehealth Addiction Treatment Utilization by Age, Race, Ethnicity, and Socioeconomic Status in California After COVID-19 Policy Changes
This cohort study found that disparities in addiction treatment utilization were not exacerbated following expansion of telehealth during the early phase of the COVID-19 pandemic. Researchers examined whether there were differences in overall and telehealth addiction treatment utilization after telehealth policy changes during the COVID-19 pandemic by age, race, ethnicity, and socioeconomic status. Additionally, the findings show that the odds of initiating addiction treatment via telehealth rose by 38.5 percentage points between 2019 and 2020.
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State Medicaid and Private Telemedicine Coverage Requirements and Telemedicine Use
Health Services Research: State Medicaid and Private Telemedicine Coverage Requirements and Telemedicine Use
Medicaid coverage of telehealth services between 2013 and 2019 was associated with significant increases in telehealth use and health care access. Medicaid telehealth coverage requirements were linked to a 6.01 percentage-point increase in the use of live video communication. Additionally, states with a Medicaid telehealth coverage requirement throughout the study period had substantially higher rates of telehealth use initially than those that added a policy. Access to covered telemedicine services could alleviate some of these barriers by eliminating the need to travel to see a provider, which may explain in part the larger response to telemedicine coverage among Medicaid enrollees.
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Telemedicine Use by Age in Louisiana Medicaid During COVID-19
Journal of Medical Internet Research: Telemedicine Use by Age in Louisiana Medicaid During COVID-19
This claims-based longitudinal analysis found that Medicaid beneficiaries between the ages of 50 and 64 had higher telehealth claims during the COVID-19 pandemic compared to those aged 18 to 34. In April 2020, the 50 to 64 age group experienced an increase of 184.09 telehealth claims per 1,000 Medicaid beneficiaries. Researchers noted that this data shows that older patients in Louisiana had higher telehealth claim rates during the COVID-19 pandemic. Also, given that telehealth use remained high in December 2020, researchers also concluded that telehealth would likely serve as a channel for maintaining integral access to care. This data could serve as a tool for policymakers to determine telehealth laws and the policies that would most assist Medicaid beneficiaries.
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