CMS Response to Alliance’s Comments
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Open in new tab 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 The current location-based enrollment structure is outdated and does not support providers new operational and privacy concerns faced in a digital age.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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Alliance Leads More than 185 Organizations in a Letter Supporting the Telehealth Expansion Act
The Alliance for Connected Care led 188 organizations in a letter urging House Ways & Means Committee leaders to advance the Telehealth Expansion Act of 2023 (H.R. 1843/S. 1001) to the full House of Representatives for consideration.
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.
The letter supported a successful effort in advocating for the favorable reporting of this bill out of the House Ways & Means Committee during a markup of the bill on June 7, 2023. See the Alliance statement here.
For more information and the Alliance’s advocacy on this policy, please click here.
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Statement on the Telehealth Expansion Act of 2023
The Alliance for Connected Care is pleased to support the Telehealth Expansion Act of 2023 (H.R. 1843/S. 1001) and applauds Representatives Steel (R-CA), Lee (D-NV), Smith (R-NE), and Schneider (D-IL) and Senators Daines (R-MT) and Cortez Masto (D-NV) for their leadership in introducing this bipartisan, bicameral legislation.
This bill would make permanent the CARES Act authority allowing employers and health plans to cover telehealth visits for individuals with high-deductible health plans coupled with a health savings account (HDHP-HSA) before having to meet their deductible. This flexibility has been critical to ensuring American families could maintain access to a range of affordable virtual care services on a pre-deductible basis throughout the COVID-19 pandemic, and is currently extended through December 31, 2024 as a result of the Consolidated Appropriations Act, 2023.
There are more than 32 million Americans with 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.
These policies are also popular among patients and plan sponsors in the commercial market. For example, a 2021 survey of health plans found that the top services most likely to improve patient satisfaction if covered pre-deductible for individuals with an HDHP-HSA were primary care visits (81 percent) and the permanent ability to offer telehealth services (64 percent).
“Millions of Americans spend thousands of dollars of their own money on medical services before their insurance kicks in. Even with the benefit of tax exclusion, high deductibles are a struggle for many individuals and families. Why wouldn’t we want to allow employers to cover telehealth, including primary care and mental health services, immediately regardless of deductible? It’s access to health care, plain and simple,” said Krista Drobac, Executive Director of the Alliance for Connected Care. “The Alliance for Connected Care is proud to support the Telehealth Expansion Act, which will ensure individuals with HDHP-HSAs continue to have ready access to virtual-care services on a permanent basis.”
The Alliance was please to lead a stakeholder letter in support of this bill, which had more than 185 organizations sign on in support. The letter supported a successful effort in advocating for the favorable reporting of this bill out of the House Ways & Means Committee during a markup of the bill on June 7, 2023.
For more information and the Alliance’s advocacy on this policy, please click here.