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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Open in new tab 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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CMS Response to Alliance’s Comments
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Alliance Submits Statement for the Record for Senate Finance Health Subcommittee Hearing on Medicare Telehealth Permanency
The Alliance for Connected Care submitted a statement for the record to the Senate Finance Committee, Subcommittee on Health for the hearing, “Ensuring Medicare Beneficiary Access: A Path to Telehealth Permanency.”
The Alliance focused its comments on:
- Recommendations for a permanent telehealth expansion that Congress should consider, including steps to ensure equitable access;
- Other non-Medicare recommendations that we believe Congress should prioritize; and
- While we generally do not believe additional telehealth guardrails are needed, we offer some options that would be operationally feasible for health care organizations to implement without significantly disrupting patient access to care.
Read the full letter here, or below.
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Alliance and Over 110 Organizations Request CMS to Ensure Telehealth Practitioners Privacy Are Protected
The Alliance for Connected Care, in partnership with the American Telemedicine Association, led 112 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 allows practitioners to render telehealth services from their home without reporting their home address on their Medicare enrollment or billing paperwork. This will end on December 31, 2023. The current location-based enrollment structure is outdated and does not support providers new operational and privacy concerns faced in a digital age.
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Alliance Leads 170 Organizations in a Letter Supporting the Telehealth Expansion Act
The Alliance for Connected Care led a letter urging House and Senate leaders to support the passage of the Telehealth Expansion Act of 2023 (H.R. 1843/S. 1001). This is legislation which the House Ways & Means Committee advanced on a bipartisan basis earlier this year.
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.
For more information and the Alliance’s advocacy on this policy, please click here.
Read the Senate Letter, signed by 170 organizations here:
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Read the House Letter, signed by over 170 organizations here:
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Social Media
170 organizations urged Senate leadership to support the Telehealth Expansion Act of 2023 (S. 1001/H.R. 1843). The Telehealth Expansion Act would allow #employers/health plans to provide covered #telehealth services to individuals with a high-deductible #health plan coupled with a health savings account (HDHP-HSA) before their deductible is met. The policy is currently set to expire December 31, 2024.
By the end of 2024, more than 32 million Americans with a high-deductible health plan coupled with a Health Savings Account (HDHP-HSA) will lose access to pre-deductible #telehealth services. 170 organizations urged Senate leadership to support the Telehealth Expansion Act of 2023 (S. 1001/H.R. 1843). Read the letter here: https://connectwithcare.org/wp-content/uploads/2023/10/October-2023-HDHP-Letter-Senate-FINAL-October-18-2023.pdf
Alliance Submits Comments on How Telehealth Can Boost Access to Care in Rural America
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The Alliance for Connected Care submitted comments to the House Ways & Means Committee request for information (RFI) on ways to incentivize access to care in rural America.
Please find the full comments below or here.
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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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For more information and the Alliance’s advocacy on this policy, please click here.
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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