Alliance and Over 150 Organizations Request CMS to Ensure Telehealth Practitioners Location Are Protected
The Alliance for Connected Care led more than 150 stakeholder organizations in a letter requesting that the Centers for Medicare and Medicaid Services (CMS) to take action on preserving the benefits of telehealth by ensuring telehealth practitioners working from a home-based (or other) location do not need to report that private residence to the federal government for purposes of either enrollment or billing.
Currently, CMS proposed, in the CY 2025 Medicare Physician Fee Schedule, an extension through 2025 of regulatory flexibility for telehealth practitioners who offer a telehealth service from their home or another location to report their currently enrolled location. However, the ability to bill a currently enrolled location does not alleviate barriers for virtual-only practitioners without a physical practice location to report other than their homes.
The signers respectfully request CMS to work with stakeholders to develop an alternate method of determining location for the purposes of payment that does not require the reporting of a home address, such as through the convening of a roundtable or a similar effort, to ensure the experiences of virtual-only practitioners are considered.
Read the full letter here or below:
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Open in new tab Alliance Letter to HHS OIG on RPM Report
The Alliance for Connected Care sent a letter to HHS OIG regarding the report on remote patient monitoring. The Alliance highlights inaccuracies and subjective nature of the report. The Alliance requests HHS OIG to consider retracting the report, and amending it to accurately reflect the way that RPM services are required to be delivered in Medicare, as well as reducing the bias language.
Please find the letter here or below.
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Letter on House Energy & Commerce Temporary Two-Year Extension
On behalf of the Alliance for Connected Care and the many patients and clinicians we represent, the Alliance wrote 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).
In addition to support for the legislation, the Alliance remains concerned with the challenging language on virtual platforms and the incident to language that is restricted to virtual providers.
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The Alliance Leads Almost 350 Stakeholders Urging for a Two Year Extension on DEA Telemedicine Flexibilities
FOR IMMEDIATE RELEASE
MEDIA CONTACT
Krista Drobac; kdrobac@connectwithcare.org
Hundreds of Stakeholders Call on Federal Leaders to Ensure Patient Care is Not Interrupted by Expiring Prescribing Flexibilities
WASHINGTON, D.C. September 10, 2024 – Today, more than 300 organizations asked Congress and the White House to intervene to ensure ongoing access to virtual prescribing for patients and providers of certain controlled substances. Stakeholders anticipate that the Drug Enforcement Administration (DEA) will dramatically limit virtual prescribing, either through new regulations or by allowing the existing flexibilities to expire.
The letters to Senate and House leadership urge Congress to include, in the end-of-year legislative package, a two-year extension of prescribing flexibilities to allow for time to achieve a balance between patient access and diversion control. The letter to the White House urges Biden Administration leaders to ensure that the DEA preserves access to critically important health care treatment for patients by providing more time more time to work details out, specifically issuing another extension of prescribing flexibilities.
The letters also highlight that the flexibility has been essential in ensuring that patients receive timely and necessary care. Continuing these practices is vital to sustaining access to treatment and addressing the ongoing health care challenges, particularly in underserved areas.
“After 16 years of waiting for action by the DEA, more than 38,000 comments on a flawed rule, and news of a second flawed rule, the DEA has demonstrated it cannot balance health care access with diversion control. What Congress asked for was simple, establish a special registration process. We now we find ourselves out of time again, and in need of another extension to help get this right,” said Krista Drobac, founder, Alliance for Connected Care.
The Ryan Haight Online Pharmacy Consumer Protection Act of 2008 requires the DEA, in conjunction with the Secretary of HHS, to promulgate permanent rules to allow practitioners to prescribe certain controlled medications via telehealth through a special registration pathway. As of today, the agency still had not done so. In the advent of the Public Health Emergency, the DEA allowed DEA-registered practitioners to issue prescriptions for certain controlled substances to patients via telemedicine without requiring an in-person medical evaluation. These flexibilities have been a lifeline for countless individuals across the country, ensuring uninterrupted access to essential mental health care, substance use treatment, end-of-life care, and many other crucial treatments during a time when in-person visits were impossible or unsafe.
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The Future of Remote Physiologic Monitoring and Current Medicare Cuts
The Alliance for Connected Care led a group letter, calling attention to the need for strong CMS support of patient access to remote monitoring services that are vital in prevention and treatment for Medicare beneficiaries. The letter was submitted to CMS through the PFS public comment process.
In the Calendar Year (CY) 2025 Medicare Physician Fee Schedule proposal, RPM code reimbursement has decreased as much as nine percent. Cumulatively, some codes been cut more than 30 percent since just 2021. While we recognize these changes are not an active policy decision, we request CMS leadership act to mitigate the harmful effect of these changes on Medicare beneficiary access.
Read more about the Alliance’s RPM priorities here.
See the full letter below or here.
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Alliance CY 2025 Medicare Hospital Outpatient Prospective Payment System (OPPS)Comments
The Alliance for Connected Care provided comments to the calendar year (CY) 2025 Medicare Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System proposed rule.
As reflected in the comments below, the Alliance urges CMS to recognize payment for genetic counselors providing care virtually, expand its proposal on virtual cardiac rehabilitation, and allow for outpatient reimbursement for RPM care management services. We believe these steps will improve the overall quality of care, lower costs, and improve the experience of Medicare beneficiaries.
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Alliance CY 2025 Medicare Physician Fee Schedule Comments
The Alliance for Connected Care provided comments to the calendar year (CY) 2025 Medicare Physician Fee Schedule (PFS) proposed rule.
As reflected in the comments below, the Alliance appreciates CMS for ensuring certainty to telehealth access to Medicare beneficiaries to the extent it could. The Alliance is committed to leveraging telehealth and remote patient monitoring to improve quality of care while also lowering costs and improving the clinician experience.
The Alliance would like to emphasize the following overarching priorities in advance of our more detailed response:
- The Alliance supports the CMS proposal for a one-year extension to provide time to address provider enrollment and billing concerns related to the provision of telehealth services form a provider’s home or non-clinical location. The Alliance seeks clarification on specific requirements related to enrollment and billing of these providers.
- 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 consider additional clinical situations in which virtual direct supervision is also acceptable. We applaud CMS for permanently allowing virtual direct supervision for lower acuity health care services provided incident to a physician.
- The Alliance applauds the CMS decision not to cover duplicative codes for telehealth services. We believe that the adoption of these codes would undermine the broader efforts of the Administration to ensure equitable access to the full spectrum of Medicare services.
- While reimbursement is a concern for many services, the Alliance is most concerned with the dramatic and continuing decline in reimbursement for remote patient monitoring. We believe that this decline presents a significant barrier for most Medicare beneficiaries to receive services that both CMS and the Alliance believe are valuable for patients with chronic conditions.
- The Alliance strongly supports permanent CMS action to protect and ensure access to audio-only telehealth when clinically appropriate and needed by the patient.
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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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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.