Alliance Comments on the 21st Century Cures Initiative
The Alliance for Connected Care provided input into refining the goals of the 21st Century Cures initiative.
The Alliance has a strong interest and member expertise in the way digital health technologies can support and expand access to care while improving patient engagement and quality. After four years of experiencing the benefits of expanded telehealth services, patients expect telehealth and remote patient monitoring as an option in their care treatment plans. We believe the Cures 2.0 effort has the potential to modernize an antiquated reimbursement system to better serve patients in need and realize the potential of digital technologies through better integration into care patterns.
To fully realize access to digital health technologies, several long-standing barriers should be focused on in the 21st Century Cures initiative:
- Permanent Medicare Telehealth Flexibilities
- Remove geographic and originating site limitations
- Remove distant site provider list restrictions
- Ensure Federally Qualified Health Centers (FQHCs), Critical Access Hospitals (CAHs), and Rural Health Clinics (RHCs) can furnish telehealth in Medicare
- Remove in-person requirements under Medicare for mental health services furnished through telehealth and telecommunications technology
- Drive better and more coordinated care for those with chronic disease by ensuring adequate reimbursement for remote patient monitoring (RPM) technology
- Work with CMS to ensure providers rendering telehealth services from their home are able to offer services without reporting their home address on their Medicare enrollment or billing paperwork.
- Encourage Additional Care Across State Lines
- Decentralize Clinical Trials To Expand Opportunity For Research Into Underserved Communities
Read the full letter here or below:
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Open in new tab Telehealth Stakeholder Letter to Congressional Leadership
The Alliance for Connected Care joined a telehealth stakeholder letter to congressional leadership, urging swift action on legislation that would extend current Medicare telehealth flexibilities.
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Alliance Wins in the Proposed Medicare Fee Schedule
Alliance Wins in the Proposed Medicare Fee Schedule
July 11, 2024
While CMS does not currently have statutory authority to waive geographic and originating site restrictions for telehealth, it has proposed a number of important steps to preserve access to telehealth in the CY2025 Physician Fee Schedule.
- Extension of provider location reporting flexibility: Proposed continuation of current policy through 2026 allowing a distant site practitioner to use their currently enrolled practice location instead of their home address when providing telehealth services from their home. The Alliance has aggressively advocated for permanent change, most recently in a June letter to CMS.
- Permanent authority for audio-only: CMS proposes to permanently allow two-way, real-time audio-only communication technology for any telehealth service furnished to a beneficiary in their home if the distant site physician or practitioner is technically capable of using an interactive telecommunications system but the patient is not capable of, or does not consent to, the use of video technology.
- Virtual Direct Supervision: CMS has proposed a new permanent authority for virtual direct supervision of incident to services. It has also continued broader existing virtual direct supervision authority through 2025. This includes the current policy allowing teaching physicians to have a virtual presence for purposes of billing for services furnished involving residents in teaching settings who are offering a virtual service.
- Rejection of separate coding for telehealth: CMS has proposed not to cover new telehealth codes that duplicate existing telehealth-eligible services covered by Medicare. The Alliance applauds this decision, which follows our advocacy this spring to ensure Medicare telehealth services remain equivalent to in-person care. We believe that telehealth is a modality for providing health care, it is not a different service.
In addition to these highlights, the Alliance will provide CMS with a detailed response to both positive and negative elements of the proposed rulemaking.
The Alliance calls on Congress to take the next step and ensure full statutory authority exists to maintain access to Medicare telehealth services in 2025.
Alliance Leads Letter to Congressional Appropriators to Support Telehealth Resource Centers FY 2025
The Alliance for Connected Care led a letter asking Congressional Appropriators to include a $14 million request for the Telehealth Resource Centers (TRC) program at the Health Resources and Services Administration (HRSA) in FY2025 appropriations.
This increase in funding would provide a critical boost to the TRCs, which saw an 800% increase in demand for telehealth assistance during the COVID-19 pandemic. Post-pandemic, demand for telehealth technical assistance remains high, with TRCs experiencing a 400% increase compared to pre-COVID-19 levels. The TRCs need at least $14M in funding in FY25 to ensure that each TRC (regional and national) can receive at least $1M each to continue to meet this demand and ensure that telehealth questions and issues can continue to be addressed.
To read the final letter, see below or click here.
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Alliance Requests CMS to Consider Administrative Burden on Telehealth Practitioners
The Alliance for Connected Care sent a letter to the Centers for Medicare and Medicaid Services (CMS) regarding ongoing decisions by CMS that will dramatically increase administrative burden for both practitioners offering telehealth services and CMS itself through the requirements for the reporting of multiple addresses for a clinician offering telehealth.
CMS currently allows telehealth practitioners who offer a telehealth service from their home or another location to report the location in which they can offer in-person care on their billing forms. This continuity in the billing of services while offering more flexible care has enabled telehealth to expand provider capacity, supported patient access to after-hours care from their existing clinicians, and has been a determining factor in the decision of many health care practitioners to remain in the workforce.
Unfortunately, this policy is set to expire after December 31, 2024. The Alliance for Connected Care respectively requests that CMS consider making permanent its existing policy allowing a practitioner to bill from their in-person practice location.
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Letter on House E&C Temporary Two-Year Extension
On behalf of the Alliance for Connected Care and the many patients and clinicians we represent, we write to support the Committee’s leadership in working to avert a pending telehealth cliff for Medicare beneficiaries and support bipartisan passage of the Telehealth Modernization Act of 2024 (H.R.7623).
The Alliance for Connected Care sent a letter to House Energy & Commerce Committee leadership in support of averting a pending telehealth cliff for Medicare beneficiaries.
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Finally – Action on Prescribing Through Telehealth
Last week, we finally saw a proposed rule – “Telemedicine Prescribing of Controlled Substances When the Practitioner and the Patient Have not had a Prior In-Person Medical Evaluation” arrive at OMB. We expect that this proposed rule will avert the current end of telehealth prescribing flexibility on December 31, 2024. However, there remains significant risk of patients losing access to care due to the rulemaking.
We also saw two major policy developments in this space last week, outlining the opportunities and risks for telehealth access.
- First – our nation’s foremost medical societies and behavioral health voices called on the Administration to ensure that patients – both child and adult – are able to receive prescriptions to non-narcotic stimulants necessary for care through telehealth.
- Second, the Department of Justice made a major arrest related to the prescribing of Adderall over the internet.
So, what does this mean?
The letter to Drug Enforcement Administration (DEA) demonstrated the widespread agreement that telehealth is absolutely crucial for the ability of psychiatrists, pediatricians, mental health professionals, and patients to offer and receive treatment. They make it clear that there is no option to go back to a world in which these providers and patients have additional barriers to health care access.
The enforcement actions by DEA put an exclamation point on their previously shared concerns with stimulant prescribing. In our view, these actions demonstrate that “wild west” period of virtual care spawned in 2020 has come to a close. The actions show that regulators are closely scrutinizing the practices of organizations that stretched the traditional boundaries of health care and are now taking important steps to rein in those who may have overstepped.
Moving forward, we hope to see a rulemaking that focuses on the special registration process for telemedicine that is required by statute, but without the significant and burdensome in-person visit requirements that were featured in the previous proposed rule – and which would have cut many patients off from access to care.
As you might expect from the updates above, a major area of debate for this rulemaking will be around non-narcotic stimulants – which were heavily restricted by the previous proposed rule. It’s clear that access to these treatments through telehealth are needed by patients and medical providers. Its also now clear that the DEA has the will and enforcement capability to monitor this space and protect patients. With a special registration process in place, the DEA would have even more tools and capability to monitor prescribing and intervene when needed.
Will an answer as simple as registration and enforcement emerge in the proposed rule? It’s unlikely. We are eagerly awaiting the details of the proposal from DEA. Ideally one that listens to clinical voices, continues investigating potential bad actors, and – most importantly – ensures the lifeline of telehealth is not severed.
Join us in advocating for continued access to telehealth!
Mental Health Groups Sent Letter on Schedule IIN Non-Narcotic Prescribing
Mental Health Groups Sent Letter on Schedule IIN Non-Narcotic Prescribing
Mental health groups are pushing the agency to allow Schedule IIN non-narcotic drugs to be prescribed without an in-person visit. Those include stimulants used to treat attention-deficit/hyperactivity disorder.
A coalition of mental health groups, including the American Psychiatric Association, the American Academy of Pediatrics and the Kennedy Forum, wrote to the DEA on Tuesday, saying that not allowing such drugs to be prescribed without an in-person visit as it previously proposed would be a mistake.
The Alliance was pleased to support the effort around this letter.
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Over 380 Clinicians Send Letter to DEA
Over 380 clinicians and practitioners signed a letter, requesting the DEA to issue a revised proposed rule to regulate the prescribing of controlled substances through telehealth as soon as possible to ensure adequate time for patients to continue existing care.
To read a full copy of the stakeholder letter, please click here.
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Letter on House W&M Temporary Two-Year Extension
On behalf of the Alliance for Connected Care and the many patients and clinicians we represent, I am writing to share our appreciation for your leadership in advancing important telehealth access – building on the dynamic hearing this spring on care in the home. Most notably, we have supported the Committee’s actions to avert the coming telehealth cliff on December 31, 2024 – both through the advancement of commercial market telehealth last year and now with a two-year extension of Medicare telehealth access.
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