Comment Letter on CY 2024 Physician Fee Schedule Proposed Rule

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.