Rather than stopping telehealth's momentum when the COVID-19 pandemic ends, provider groups want CMS to press forward by allowing more providers to take part in virtual care and boosting reimbursements for telehealth services.
In their comments on CMS' emergency changes to the Medicare program, provider groups praised the agency for its unprecedented extension of telehealth benefits during the COVID-19 pandemic. But they argued that the federal government should make permanent changes following the tectonic shift in telehealth during the past few months.
"It is imperative that the progress that has been made since March continue when the (public health emergency) ends," the Association of American Medical Colleges said.
AAMC asked the agency to extend the telehealth flexibilities and waivers for one year beyond the end of the public health emergency to give Congress and federal regulators time to act. Public officials across the board support the long-term expansion of telehealth services, so it's likely a matter of when, not if the changes will be made permanent.
Hospitals, medical groups and clinicians also want CMS to allow more providers to deliver higher levels of telehealth services to beneficiaries. For instance, there has been an increase in the number of inpatient interprofessional consultations during the COVID-19 pandemic, but CMS limits how often they can occur. Hospitals want the agency to lift the restrictions so that they can respond quickly to the healthcare needs COVID-19 patients without putting other patients, or their finances, at-risk.
Likewise, CMS has said that telehealth visits cannot replace in-person or home health visits under Medicare's home health benefit, a restriction that's made it more difficult for providers to deliver care to worried seniors.
"We have heard of instances where patients are refusing in-home care out of fear of contracting COVID-19. In these instances, telehealth may be the only possible avenue to access the patient and provide them with the healthcare they require," the American Association of Nurse Practitioners said.
Pharmacists are asking CMS for additional flexibilities and more forgiving enforcement discretion to allow them to assist with COVID-19 testing and other services, including clarifications about what services they can deliver and bill Medicare for, given the vague language included in CMS' interim final rule.
There "remains a number of logistical, pharmacist and pharmacy payment, and patient access issues that must be addressed in order to fully implement the pharmacist testing guidance and create a pathway for all pharmacies and pharmacists to offer COVID-19 point of care testing for all patients," the American Pharmacists Association said.
Provider groups are asking for increased reimbursement for telephone-only telehealth services too. CMS temporarily approved payment for telephone-only evaluation and management, or E/M, services in March. But providers say the reimbursements are too low because they don't reflect the level of services that clinicians are delivering during the pandemic. Some patients are unwilling or unable to use video-based telehealth services, especially beneficiaries that are older and poorer.
"In many instances, the way our members are providing care to their patients by telephone is far more akin to a standard, face-to-face E/M visit, or a visit when it is conducted using real-time audiovisual technology," the American Academy of Physical Medicine and Rehabilitation said.
The National Association of ACOs and eight other groups representing providers in accountable care organizations asked CMS to take several actions in response to the COVID-19 pandemic. They want the agency to give ACOs the option to give up some of their shared savings in exchange for protection against financial losses and extend the deadline for the Medicare Shared Saving Program. ACO providers also want CMS to overturn its decision to cancel the 2021 MSSP application cycle and to make ACO shared savings and Advanced APM bonus payments as soon as possible, according to a joint letter.
In addition, ambulatory surgical centers suggested that CMS' new Hospital Without Walls policy may not give them enough flexibility to enroll in Medicare as a hospital during a public health emergency, citing evidence that only a dozen or so ambulatory surgical centers and freestanding emergency departments had applied as of April 30.
"In the event of another wave of the virus, we encourage CMS to consider additional flexibilities, in consultation with the ASC community, that would allow ASCs to provide surge capacity," said the Alliance for Orthopedic Solutions.