Alliance Submits Statement for the Record for House Energy & Commerce Hearing on Telehealth Legislation
The Alliance for Connected Care submitted a statement for the record to the House Energy & Commerce Committee, Health Subcommittee for the legislative hearing, “Legislative Proposals to Support Patient Access to Telehealth Services.”
The Alliance focused its comments on:
- The need for urgent action in extending Medicare telehealth provisions through December 31, 2024 to provide certainty around the future of telehealth.
- Endorsed telehealth legislation and urged the Subcommittee to advance bipartisan legislation.
- Several recommendations that Committee should consider to permanently expand access to telehealth.
- Recommendations for fraud, waste, and abuse.
Read the full letter here, or below.
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Open in new tab Alliance Co-Leads Letter to DEA Urging Action on Telehealth Rule Crucial for Mental Health, Substance Use Disorders
FOR IMMEDIATE RELEASE
Stakeholders Send Letter to DEA Urging Action on Telehealth Rule Crucial for Mental Health, Substance Use Disorders
WASHINGTON, DC, APRIL 2, 2024 – The Alliance for Connected Care, American Telemedicine Association, ATA Action, the Consumer Technology Association, and the Healthcare Information and Management Systems Society, co-leading the effort, submitted a letter to the U.S. Drug Enforcement Administration (DEA) requesting the expedited release of a revised proposed rule to permit and regulate the prescribing of controlled substances through telehealth. The letter was signed by 214 stakeholders. Current flexibilities allowing for the remote prescribing of controlled substances are set to expire at the end of this year, necessitating regulatory action to ensure their continuation.
Stakeholders praised the DEA for their leadership and actions taken to ensure continued patient access to care be delivered through telemedicine in advance of the final telemedicine regulations expiring at the end of this year. The letter also urged DEA to propose the updated rules immediately for the following reasons:
- To ensure stakeholders have adequate time to provide feedback on any policy proposal.
- If DEA were to create a special registration process for telehealth prescribers, as proposed by DEA and many stakeholders, substantial operational lead-time would be needed to implement the new process and comply with other potential operational requirements and guardrails.
- A rulemaking late in the year that makes significant policy changes would affect the ability of patients and clinicians to make appointments and ensure consistent access to care.
- There will be operational staff training needs for pharmacies and other parts of the healthcare delivery system to ensure patients uninterrupted access to needed medical treatments offered through telehealth.
- DEA’s national leadership is needed to set a clear path forward for the nation and to encourage more consistent definitions and aligned requirements from state regulatory bodies – to encourage care in our most underserved areas, without geographic barriers limiting access to care.
To read a full copy of the stakeholder letter, please click here.
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Alliance Statement – Correcting the Record for House Ways & Means Hearing on Care in the Home
Correcting the Record on Telehealth
March 2024
During the March 12 House Ways and Means Committee Hearing on Expanding Access to Care at Home in Rural and Underserved Communities, a number of already disproven myths about telehealth were publicly repeated. While broader understanding of the benefits and use of telehealth have come a long way, these outdated misconceptions continue to undermine policymaking and must be corrected.
Importantly, the Alliance and its members believe that an in-person visit requirement is never the right guardrail for a telehealth service – because these requirements harm patients with access challenges, such those who are frail or homebound, have transportation issues, or live in rural or underserved areas. Similarly, we believe that a clinician’s time has the same value, no matter if they are supporting a patient virtually or in-person.
Correction #1 – Telehealth Does Not Lead to Increased Fraud
In 2021, the Department of Health and Human Services (HHS) Office of Inspector General (OIG) released a statement clarifying the difference between telehealth fraud and “telefraud”, with the latter involving the use of telemarketing to defraud patients. The letter emphasizes OIG’s investigations, which found that perpetrators billed fraudulently for other items and services, like durable medical equipment or genetic tests, but did not bill for a telehealth visit. Importantly, OIG did not document telehealth services fraud.
In February of 2024, OIG released a report, which found that telehealth services provided to Medicare beneficiaries complied with Medicare requirements and did not show evidence of fraud. The report examined telehealth services provided to Medicare beneficiaries from March 2020 through November 2020, the peak of telehealth usage.
Telehealth is no more susceptible to billing fraud than in-person services. Rather than focusing on telehealth, Congress and the Administration should continue to focus on identifying and addressing fraudulent behavior across the entire Medicare program through tools like a stronger provider enrollment process and enhanced monitoring.
Correction #2 – Telehealth Has Not Been Shown to Drive Overutilization
The Assistant Secretary for Planning and Evaluation (ASPE) has consistently found that the utilization of telehealth among Medicare fee-for-service (FFS) beneficiaries continue to be above pre-pandemic levels, but is not showing signs of growth. As you might expect telehealth service utilization is higher among vulnerable populations due to their greater need for care from the severity and complexity of their illness.
The Alliance and many other organizations have looked telehealth utilization in the context of total Medicare utilization and shown that telehealth services have generally leveled off around 5 percent, while total utilization has not significantly grown. Telehealth did not add to the total volume of Medicare services in nearly all of the telehealth-eligible services examined.
Robust research has found that telehealth substitutes for in-person care rather than contribute to overutilization. An Agency for Healthcare Research and Quality (AHRQ) funded study, analyzed more than four million primary care encounters, and found little change in health care utilization as telehealth became widely accessed.
The Alliance’s commissioned independent Medicare claims data also found no evidence that patients initiating care who used telehealth had more E&M revisits for the same medical issue than patients with in-person visits.
A study conducted by Epic Research found that follow-up rates were less for telehealth than in-person office visits. Most specialties have greater rates of same-specialty in-person follow-up in the 90 days after in-person office visits than after telehealth visits.
Correction #3 – Telehealth Has Not Been Shown to Increase Spending
A growing body of evidence has found that telehealth is associated with lower no-show and cancellation rates. No-shows cost health care providers $150 billion every year.
An AHRQ-funded study fund that telehealth reduced primary care spending due to lower emergency department utilization and inpatient hospitalizations.
The Alliance’s commissioned independent Medicare claims data also found that the average per service cost of an E&M telehealth visit to the Medicare program is less than in-person services by approximately 20 percent. The reason for this difference was that telehealth clinicians generally billed shorter visit codes than in-person providers.
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Alliance Submits Statement for the Record for House Ways & Means Hearing on Care in the Home
The Alliance for Connected Care submitted a statement for the record to the House Ways & Means Committee for the hearing, “Enhancing Access to Care at Home in Rural and Underserved Communities.”
The Alliance focused its comments on:
- The need for urgent action in extending Medicare telehealth provisions through December 31, 2024 to provide certainty around the future of telehealth.
- Committee to work with the Centers for Medicare and Medicaid Services (CMS) to ensure virtual care meet the needs of Medicare beneficiaries is valuable and should be continued.
- Several recommendations that Committee should consider to permanently expand access to telehealth, particularly for those patients in rural and underserved areas.
- Recommendations for fraud, waste, and abuse.
Read the full letter here, or below. The Alliance also released a statement correcting the record on some misconceptions mentioned from the hearing.
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Alliance Joins Statement to DEA on Geographic Red Flag in Telemedicine
The Alliance for Connected Care joined over 45 organizations in a statement to the Drug Enforcement Administration (DEA), requesting explicit guidance to the pharmacy community that the geography of a prescriber in relation to the patient or the pharmacy should not be a “red flag” when a prescription is a result of a telehealth visit.
Read the letter here or below:
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Alliance Leads Over 200 Organizations in a Letter Urging Congress to Act on Telehealth
The Alliance for Connected Care convened well over 200 organizations on a letter, urging congressional leaders to act on telehealth earlier this year, to allow for implementation time prior to the expiration of statutory restriction on December 31, 2024.
Without timely and decisive action from Congress, many Americans risk losing access to telehealth services they rely upon due to challenges with 2024 timelines needed to ensure 2025 benefits – such as federal payment rules, employer and health plan benefit decisions, and health provider workforce decisions.
For more information and the Alliance’s advocacy, please click here.
Read the letter here or below:
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Alliance Joins Letter In Support of the States Handling Access to Reciprocity for Employment (SHARE) Act
The Alliance for Connected Care joined over 20 organizations in a stakeholder letter supporting the States Handling Access to Reciprocity for Employment (SHARE) Act (H.R. 1310). The bill would authorize the use of FBI criminal history record information for administration of interstate compacts.
Read the letter here or below:
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Alliance for Connected Care Announces New Members and Leadership
FOR IMMEDIATE RELEASE
MEDIA CONTACT
Chris Adamec; cadamec@connectwithcare.org
Alliance for Connected Care Announces New Members and Leadership
WASHINGTON, D.C. February 13, 2024 – Today, the Alliance for Connected Care (“the Alliance”) welcomes several clinician and patient advocacy organizations to its membership, and a new Executive Director. During this critical policy year for telehealth and remote patient monitoring, it is essential to have a wide range of leading voices together in a coalition. With patients, hospital systems, physicians, nurses, technology innovators, retailers and health plans as members, the Alliance truly speaks with a cross-sector voice.
Additionally, Chris Adamec will take over as executive director of the Alliance, continuing to drive forward coalition advocacy to ensure patients have access to, and clinicians are reimbursed for virtual care. With more than 15 years of experience in Washington, and four years with the Alliance, Mr. Adamec has relationships across the stakeholder spectrum, in Congress, the Executive Branch and deeply understands the policy.
Founder, Krista Drobac, will continue to serve the Alliance through strategic guidance and thought leadership. “As the Alliance celebrates its 10-year anniversary, we have seen unprecedented progress in access to telehealth, and Chris is the best person to take this uniquely positioned group into the next chapter. Over the last four years, Chris has impressively led the Alliance’s advocacy on the Hill, the Administration, and with stakeholders. I am confident that the Alliance will grow and flourish in his capable hands,” said Krista Drobac, Founder of the Alliance for Connected Care.
Following are new Alliance for Connected Care members in 2024:
- Alzheimer’s Foundation
- American Academy of Neurology
- American Academy of Physician Associates
- American Association for Marriage and Family Therapy
- American Association of Nurse Practitioners
- American Association of Suicidology
- American Heart Association
- American Osteopathic Association
- American Physical Therapy Association
- Association for Behavioral Health and Wellness
- Compassion & Choices
- National Council of State Boards of Nursing (NCSBN)
- PAN Foundation
“I am thrilled to expand our membership with additional clinician specialty and patient advocacy voices, to enhance and elevate our work ensuring continued access to care provided through telehealth and remote patient monitoring,” said Chris Adamec, executive director of the Alliance. “Simple to access and simple to bill virtual care is key to our shared goals of expanding access to safe, high-quality health care.”
As telehealth and remote patient monitoring continues to be integrated into the standard of care, it is important to include the clinician perspective as they ensure patients receive safe, high-quality care using connected care technology. The Alliance is dedicated to creating a statutory and regulatory environment to ensure continued use of telehealth and remote patient monitoring.
Several new Alliance members offered comments on joining the Alliance:
“The PAN Foundation was part of the Alliance advisory board where we supported the Alliance’s efforts to push for policies that ensure continued access to telehealth services. Today, we are thrilled to join the Alliance as a member as we continue our efforts advocating for permanent telehealth polices, including audio-only services, to increase equitable access for all.” Amy Niles, Chief Advocacy and Engagement Officer, PAN Foundation
“The American Association for Marriage and Family Therapy was part of the Alliance advisory board. As an organization representing the professional interests of over 70,000 licensed marriage and family therapists, we are excited to join the Alliance as a member and support the mission for permanent access to virtual care for behavioral health providers and other clinicians.” Roger D. Smith, J.D., Chief Advocacy Officer & General Counsel, American Association for Marriage and Family Therapy
“Compassion & Choices proudly served on the Alliance advisory board to help address the need for permanent telehealth access for terminally ill patients. As the nation’s oldest and largest nonprofit organization working to improve end-of-life care, we are eager to join the Alliance as a member to advocate for easier patient healthcare access through telehealth.” Bernadette Nunley, National Director of Policy, Compassion & Choices
“The Association for Behavioral Health and Wellness (ABHW), which represents health payers who provide mental health and substance use disorder benefits to over 200 million people, is delighted to join the Alliance. We are especially looking forward to working with our Alliance partners on ensuring that buprenorphine can be prescribed through telehealth and eliminating the six-month in-person requirement for tele-mental health care.” Pamela Greenberg, President & CEO, Association for Behavioral Health and Wellness
“The American Academy of Physician Associates, representing more than 168,000 PAs, is honored to be a part of the Alliance for Connected Care. PAs are driven by a commitment to expanding patient access to high-quality medical care, and telehealth is a powerful tool for ensuring more patients get the care they need, when they need it.” Tate Heuer, Vice President, Federal Advocacy, American Academy of Physician Associates
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The Alliance is dedicated to creating a statutory and regulatory environment in which patients can receive and providers can deliver safe, high-quality care using connected care technology. Our members are leading health care and technology organizations from across the spectrum, representing health providers and systems, health payers, technology innovators, and patient and clinician organizations who wish to better utilize the opportunities created by telehealth and remote patient monitoring. For more information, please visit https://www.connectwithcare.org.
Alliance for Connected Care Opposes Duplicate Coding for Telehealth Services
The Alliance for Connected Care sent a letter to the Centers for Medicare and Medicaid Services (CMS) regarding the consideration of new telehealth codes as proposed by the American Medical Association (AMA) in 2023.
The AMA Relative Value Scale Update (RUC) Committee in May proposed 17-20 new telehealth codes to be considered in the CMS Medicare Telehealth Services List. The Alliance and its members oppose the creation of new telehealth codes that duplicate services already covered by the Medicare program for the following reasons:
- Telehealth is a modality of care, not a different service. It is therefore inappropriate for CMS to adopt multiple codes for the same service.
- Telehealth has expanded access to care for underserved and rural populations. The complexity and potential payment variation created by duplicate codes would hinder CMS’s health equity priorities.
- The 17 new codes would leave out 200 services and outpatient codes which telehealth is currently used as a modality for.
- There could be significant patient access and operational impacts as the new codes are adopted.
Read the full letter here, or below.
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Alliance for Connected Care Urges AMA to Ensure Coding for RPM and RTM Accurately Represents Clinical Utilization
The Alliance for Connected Care sent a letter to the American Medical Association’s (AMA) CPT Editorial Panel in response to its February 2024 meeting agenda, which includes Tab 50 – Remote Monitoring. The public agenda seems to indicate major revisions to remote physiologic monitoring (RPM) and remote therapeutic monitoring (RTM).
The Alliance is concerned that the revisions to RPM and RTM codes because we do not believe these changes would improve a clinician’s ability to manage care and we are concerned with downstream implications of this change – such as the potential exacerbation of concerns with appropriate utilization and practice expense calculations for the relevant device codes.
The Alliance would like to emphasize four overarching themes around which our response is based:
- The Alliance appreciates the proposal to simplify RPM and RTM coding. However, given the significance of the change, we strongly believe the panel should not finalize this proposal without significant additional input and potential modifications from a wider range of stakeholders.
- The Alliance believes that RPM and RTM should remain separate for the time being due to different clinical use cases, the evolving nature of the technologies involved, and the relatively new nature of RTM coverage.
- The Alliance and its members are concerned with current and potential restrictions on overlapping RPM/RTM services across multiple clinicians and different monitoring services and the implications of this change on those concerns. We believe that simplifying coding like the application proposes would make it harder for payers to support multiple clinicians providing clinically distinct services, exacerbating this ongoing challenge.
- While the Alliance agrees that RPM and RTM coding could be simplified and improved, we believe there are other priorities to consider in this conversation, such as addressing uncompensated care for the 20-minute threshold for reimbursement, changes to the calculation of direct practice expense, and coding to support the reporting of multiple medical devices for different conditions.
Read the full letter here, or below.
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