Alliance Submits Comments to House Ways & Means Committee on America’s Mental Health
The Alliance for Connected Care submitted a letter to the House Ways & Means Committee providing input to the Committee hearing on “America’s Mental Health Crisis.”
Our letter summarizes the following recommendations:
- Congress should permanently remove obstructive in-person requirements on mental health through telehealth.
- Congress should move to fully remove outdated originating site requirements on telehealth.
- Congress should ensure continued access to audio-only mental health care.
- Congress should ensure Federally Qualified Health Centers (FQHCs), Critical Access Hospitals (CAHs), and Rural Health Clinics can furnish telehealth in Medicare.
- Congress should work with Centers for Medicare and Medicaid Services (CMS) to address provider enrollment concerns and facilitate actions to reduce provider burdens.
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Open in new tab More than 330 Stakeholders Seek Leadership from Congress to Create Permanent Comprehensive Telehealth Reform
Washington, DC, January 31, 2022 – Today, more than 330 organizations sent a letter to Congress urging their leadership in facilitating a pathway to comprehensive permanent telehealth reform that would provide certainty to patients and our nation’s healthcare providers while providing sufficient time for Congress and the administration to analyze the impact of telehealth on patient care. The letter was co-led by the Alliance for Connected Care, American Telemedicine Association (ATA), College of Healthcare Information Management Executives (CHIME), Consumer Technology Association (CTA), Executives for Health Innovation (EHI), Health Innovation Alliance, HIMSS, Partnership to Advance Virtual Care, and the Personal Connected Health Alliance (PCHAlliance).
While the Biden Administration may elect to extend the COVID-19 public health emergency (PHE), the fact that the PHE determination must be renewed every 90 days and could end later this year is creating significant uncertainty for the U.S. healthcare system. The letter calls for Congress to advance permanent telehealth reform focused on the following specific priorities:
- Authorize the continuation of all current telehealth waivers through December 31, 2024;
- Require HHS to complete all feasible evaluations related to telehealth by fall 2023 and combine findings into a single overarching dashboard with recommendations to inform permanent telehealth legislation by Congress; and
- Pass permanent, evidence-based telehealth legislation for implementation in 2024.
Virtual care is now a fundamental part of the U.S. healthcare system, and it will improve patient access to high-quality care well beyond the COVID-19 pandemic. Patient satisfaction surveys and claims data from CMS and private health plans demonstrate that many Americans have come to see telehealth as one of the most positive improvements to our nation’s healthcare system in recent memory. Importantly, a majority of U.S. voters believe Congress should protect their ability and choice to see a provider via telehealth post-pandemic.
Download the letter here.
The following quotes are from the organizations co-leading the letter:
“Congress must act to provide more certainty to beneficiaries and healthcare providers alike, while ensuring sufficient time is taken to analyze the impact of telehealth on patient care throughout the pandemic to inform permanent telehealth reform,” said Krista Drobac, Executive Director, Alliance for Connected Care. “Extending the current telehealth waivers – both those authorized by Congress and those allowed under presidential emergency powers – are critical to ensure patients can continue to access needed healthcare services and to allow providers to continue utilizing the telehealth infrastructure implemented throughout the pandemic.”
“Now is the time to give certainty to the millions of Americans who have come to rely on virtual care and give healthcare providers the tools they need to continue to deliver uninterrupted, quality care to their patients,” said Kyle Zebley, Vice President, Public Policy, American Telemedicine Association (ATA) and Executive Director, ATA Action. “This is a pivotal moment for Congress to act and secure a bipartisan win, while taking much-needed steps to modernize our healthcare system. The ATA pledges to continue to do all we can to work with our Congressional telehealth champions to secure passage of telehealth provisions as soon as possible.”
“Throughout the course of the pandemic, we have heard a chorus of support from our members related to the success they are experiencing with telehealth and its reported widespread use and support by patients. Keeping the telehealth waivers in place through 2024 will ensure that patients and providers will not abruptly lose access to this successful care delivery method, while giving Congress additional time to work on comprehensive telehealth reform,” noted Russell Branzell, President & CEO, CHIME.
“The pandemic has shown the transformative role virtual care can play in our overall healthcare system, especially ensuring quality care is accessible to as many people as possible. The waivers were a key part in allowing healthcare providers to meet patients where they live, and we risk reversing the great progress we have seen if we go back to the way things were prior to the pandemic,” said René Quashie, Vice President, Policy and Regulatory Affairs, Digital Health, Consumer Technology Association.
“EHI is proud to join in leading this effort to urge Congress to act now on telehealth,” said Jen Covich Bordenick, CEO, Executives for Health Innovation (EHI). “The waivers currently in place have been crucial in allowing patients to access care when and where they need it during this unprecedented time. We cannot risk an abrupt end to these waivers at the end of the COVID-19 public health emergency period. Congress must act to extend these waivers so telehealth can continue while working toward permanent reform.”
“Congress should give seniors the option to use telehealth beyond this pandemic with a clean expansion through the end of 2024. This action will give certainty that these services will continue while working towards the ultimate goal of permanent reform,” said Brett Meeks, Health Innovation Alliance.
“When the COVID-19 pandemic began exposing gaps in our healthcare system, telehealth enabled critical access to high-quality care for patients and providers alike. Over the past two years, millions of Americans have gained firsthand experience with the benefits of telehealth and other virtual care tools, and they want to keep those benefits,” said Tom Leary, Senior Vice President and Head of Government Relations, HIMSS. “With so much uncertainty remaining around telehealth permanence, we now call on Congress to ensure millions of Americans don’t lose access to this care and to take action to enact comprehensive telehealth reform.”
“As Congress works toward a pathway for comprehensive telehealth reform, it is essential that current telehealth waivers be extended through at least 2024,” said Mara McDermott, Executive Director, Partnership to Advance Virtual Care. “Patients and providers alike need more certainty in care planning than afforded to them through the extension of the PHE every 90 days.”
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More Than 125 Organizations Urge Congress to Reinstate Virtual Care Access for Individuals with HDHP-HSAs
Letter to Congressional Leaders Stresses Urgency of Reinstating Telehealth Safe Harbor
Washington, DC – UPDATED – January 21, 2022 – Today, more than 125 organizations sent a letter to Congress to urge policymakers to reinstate the telehealth safe harbor enacted in the CARES Act that enabled employers and health plans to provide pre-deductible coverage for telehealth services for individuals with high-deductible health plans coupled with Health Savings Accounts (HDHP-HSAs). The letter was convened by the Alliance for Connected Care and includes a diverse mix of signers including patient groups, clinician organizations, employer coalitions, and digital health platforms.
During the pandemic, Congress took swift action as part of the CARES Act to ensure employees could receive covered telehealth services before their deductible is met by allowing employers to provide pre-deductible coverage for such services for individuals with HDHP-HSAs. This safe harbor was not tied to the public health emergency (PHE), and unfortunately expired on December 31, 2021.
The ability to offer pre-deductible telehealth services for employees is a meaningful expansion of health care access for the 32 million Americans with HDHP-HSAs. Congress must act soon to reinstate the virtual care provisions in the CARES Act for individuals with HDHP-HSAs so that millions of Americans can once again access these lifesaving telehealth services on a pre-deductible basis.
“During the COVID-19 pandemic, Congress enabled employers to offer pre-deductible coverage for telehealth services, expanding access to care and reducing out-of-pocket costs for millions of Americans. Unfortunately, this flexibility expired on December 31, 2021 despite the ongoing pandemic and recent surge in cases due to the Omicron variant,” said Alliance for Connected Care executive director Krista Drobac. “This was the first pandemic-era telehealth policy to expire, which has and will continue to impact access to needed virtual care services for millions of Americans if Congress does not act to reinstate this provision.”
Bipartisan and widely supported legislation has been introduced in the U.S. Senate and House of Representatives that would extend this access for patients. The Telehealth Expansion Act of 2021 (S. 1704/H.R. 5981) would permanently extend the CARES Act authority for employers and health plans to offer pre-deductible coverage for telehealth services for individuals with HDHP-HSAs. The Primary and Virtual Care Affordability Act (H.R. 5541) would extend this CARES Act authority through December 31, 2023, and expand this provision to primary care. We strongly urge Congress to take up and consider this legislation and to retroactively reinstate this provision as part of the next possible legislative vehicle.
To read the full letter to Committee leadership, click here. To read the full letter to Congressional leadership, click here or see below. For background information on this issue, click here.
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CMS releases an update to the State Medicaid & CHIP Telehealth Toolkit
Today, the Centers for Medicare & Medicaid Services (CMS) released updates to the State Medicaid & CHIP Telehealth Toolkit: Policy Considerations for States Expanding Use of Telehealth, COVID-19 Version and the Supplement to clarify that states may deliver covered services via audio-only telehealth both during the COVID-19 Public Health Emergency (PHE) and beyond.
This release provides additional support state Medicaid and CHIP agencies in their adoption and implementation of telehealth.
Alliance Statement on the Telehealth Expansion Act of 2021
STATEMENT ON THE TELEHEALTH EXPANSION ACT OF 2021
November 17, 2021
WASHINGTON DC – There are more than 35 million Americans with high-deductible health plans coupled with a Health Savings Account (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. Through the CARES Act, Congress gave employers the ability to provide free or reduced telehealth services to their employees during the pandemic by creating a telehealth safe harbor from certain high deductible health plan rules.
The Alliance for Connected Care (“The Alliance”) is pleased to support the Telehealth Expansion Act of 2021 (S. 1704/H.R. 5981) and applauds Senators Steve Daines (R-MT) and Catherine Cortez Masto (D-NV) and Representatives Michelle Steel (R-CA) and Susie Lee (D-NV) for their leadership in introducing this bipartisan, bicameral bill. This legislation would permanently extend the CARES Act authority for employers and health plans to subsidize telehealth visits for individuals with HDHP-HSAs, which is currently set to expire on December 31, 2021.
“During the COVID-19 pandemic, Congress enabled employers to offer pre-deductible coverage for telehealth services, expanding access to care and reducing out-of-pocket costs for millions of Americans,” said Alliance for Connected Care executive director Krista Drobac. “This bill will ensure individuals with HDHP-HSAs continue to have ready access to virtual-care services while remaining eligible to make and receive contributions to an HSA.”
A full statement that the Alliance made during the Senate introduction of the bill in May 2021 can be found here and below:
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Home Blood Pressure Telemonitoring With Remote Hypertension Management in a Rural and Low-Income Population
Home Blood Pressure Telemonitoring With Remote Hypertension Management in a Rural and Low-Income Population
The 2017 American College of Cardiology/American Heart Association blood pressure (BP) guideline provides a Class IA recommendation for the use of home BP monitoring, team-based care, and telehealth strategies to improve BP control among patients with hypertension.1 However, most studies have been conducted in integrated health systems among White populations with higher socioeconomic status. This study aimed to evaluate the feasibility, safety, and effectiveness of home BP telemonitoring with remote hypertension management among a predominately rural and low-income population.
Alliance Submits Comments to Senate Finance Committee on Mental Health
The Alliance for Connected Care submitted a letter to the Senate Finance Committee providing input into the development of bipartisan legislation to enhance behavioral health and substance use disorder care for all Americans.
Our letter includes recommendations to answer the following questions:
- What policies would encourage greater behavioral health care provider participation in these federal programs? What barriers, particularly with respect to the physician and non-physician workforce, prevent patients from accessing needed behavioral health care services?
- Should federal licensing and scope of practice requirements be modified to reduce barriers for behavioral health care workers seeking to participate in federal health care programs? If so, how?
- What programs, policies, data, or technology are needed to improve patient transitions between levels of care and providers?
- How can Congress craft policies to expand telehealth without exacerbating disparities in access to behavioral health care? How has the expanded scope of Medicare coverage of telehealth for behavioral health services during the COVID-19 pandemic impacted access to care?
- How should audio-only forms of telehealth for mental and behavioral health services be covered and paid for under Medicare, relative to audio-visual forms of telehealth for the same services? Are there specific mental health and behavioral health services for which the visual component of a telehealth visit is particularly important, and for which an audio-only visit would not be appropriate? For which specific mental health and behavioral health services is there no clinically meaningful difference between audio-visual and audio-only formats of telehealth? How does the level of severity of a mental illness impact the appropriateness of a telehealth visit?
- Should Congress make permanent the COVID-19 flexibilities for providing telehealth services for behavioral health care (in addition to flexibilities already provided on a permanent basis in the SUPPORT for Patients and Communities Act and the Consolidated Appropriations Act, 2021)? If so, which services, specifically? What safeguards should be included for beneficiaries and taxpayers?
- What legislative strategies could be used to ensure that care provided via telehealth is high-quality and cost-effective?
- What barriers exist to accessing telehealth services, especially with respect to availability and use of technology required to provide or receive such services?
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Summary: CY 2022 Final Physician Fee Schedule
On November 2, 2021, CMS issued the final Calendar Year 2022 (CY2022) Physician Fee Schedule (PFS), which makes payment and policy changes under Medicare Part B.
View a summary produced by the Alliance for Connected Care here. Additional links are provided below:
Overview of Major Policies
CMS has finalized its proposal 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. In addition, CMS is adding CPT codes 93797 and 93798 and HCPCS codes G0422 and G0423 to the Category 3 Medicare telehealth services list. These codes relate to outpatient cardiac rehabilitation and intensive cardiac rehabilitation.
CMS finalized its proposal 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 has also finalized policy 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. Note that CMS had originally included an additional parameter for patients who do “not wish to use” audio-video, however, CMS has eliminated the patient’s choice to refuse audio-video in the final rule.
CMS has also finalized its proposal to require an in-person visit be provided by the physician or practitioner furnishing mental health telehealth services within 6 months prior to the initial telehealth service, and at least once every 12 months – instead of the proposed 6 months – thereafter.
- CMS is allowing for limited exceptions to the 12 month in-person requirement. Specifically, if the patient and practitioner agree that the benefits of an in-person, non-telehealth service within 12 months of the mental health telehealth service are outweighed by risks and burdens associated with an in-person service, and the basis for that decision is documented in the patient’s medical record, the in-person visit requirement will not apply for that particular 12-month period.
- CMS notes that there is no exception to the statutory requirement that the physician or practitioner must furnish to the beneficiary an in-person, non-telehealth service within 6 months prior to initiation of mental health services via telehealth.
Finally, in response to comments that CMS implement a broad definition of the term “home” in terms of mental healthcare delivery site, CMS has clarified that the definition of home can include temporary lodging, such as hotels and homeless shelters. Furthermore, CMS notes that in circumstances where the patient, for privacy or other personal reasons, chooses to travel a short distance from the exact home location during a telehealth service, the service is still considered to be furnished “in the home of an individual.”
Below is a summary of key payment and policy changes within the rule.
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Alliance signs letter urging Congress to expand telehealth options for employees
On November 1, the Alliance for Connected Care and nearly 50 stakeholder groups sent a letter to Congress urging lawmakers to make permanent the current regulatory flexibility that allows telehealth and remote care services to be treated as an excepted benefit for certain employees.
Including standalone telehealth as an excepted benefit will help ensure hardworking Americans can access high-quality, cost-effective care when and where they need it most, regardless of employment status. Without Congressional action, employers will be unable to offer basic virtual health services to millions of Americans in part-time and seasonal jobs or workers otherwise not participating in their employer’s full medical plan.
The COVID-19 pandemic has illustrated the immense benefits of telehealth and remote care services. American workers want these benefits, and employers want to provide them. With temporary flexibilities that allowed employers to fill gaps in care set to expire, this letter urges Congress to consider making permanent the current policies that allow telehealth and remote care services to be treated as an excepted benefit.
To read the full letter, click here or see below:
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