The American Telemedicine Association and ATA Action, in a letter to the Centers for Medicare and Medicaid Services, seeks to preserve pandemic-era Medicare telehealth flexibilities that it says are responsible for improving access to healthcare across the U.S.

Telehealth plays "a crucial role in ensuring timely, appropriate and expanded access to care for millions of Americans," the organizations said in a statement Wednesday, and CMS should continue to engage stakeholders to ensure services are covered and that telehealth reimbursement rates are fair.

WHY IT MATTERS

Without an extension or legislative change to the 2025 Physician Fee Schedule when it expires at the close of 2024, telehealth would essentially downshift to limited coverage of services to certain rural areas and specific physical locations, the organizations said.

"Without Congressional action before year-end, we’re not just going to get dragged back to how telehealth looked in January of 2020, we’re going to get dragged all the way back to 1997," when federal legislators passed Section 1834(m) of the Social Security Act, Kyle Zebley, senior vice president, public policy at ATA and ATA Action executive director, said in a statement.

"These outdated limitations would undo over a half-decade of meaningful and substantial progress, and reverting to these old restrictions will severely hamper access to telehealth services that millions of Americans now rely on," he explained.

Specifically, the telehealth organizations asked in their letter to CMS Administrator Chiquita Brooks-LaSure to:

• Waive geographic and originating site restrictions.
• Maintain coverage for audio-only services.
• Allow reimbursement for telehealth to Rural Health Clinics and Federally Qualified Health Centers.
• Delay the telemental health prior in-person requirement.
• Maintain the expansion of the Medicare Telehealth Provider list to include physical, occupational and speech therapies.
• Permit access virtual cardiac and pulmonary rehabilitation services.
• Preserve the Acute Hospital Care at Home Program.
• Allow virtual diabetes prevention platforms and supplies to participate in the Medicare Diabetes Prevention Program.

"We strongly believe that Congress will maintain the Medicare telehealth flexibilities after 2024," the organizations said in their comment letter.

"Once Congress officially enacts telehealth legislation, we urge the administration, in coordination with CMS, to quickly issue guidance to providers and others within the industry to eliminate confusion and ensure the smooth implementation of regulatory telehealth policies beyond 2024."

They also discussed several areas where they feel the agency falls short in bolstering telehealth services, including remote patient monitoring.

"We are deeply concerned that CMS has not addressed the significant issues raised by digital health stakeholders regarding the 16-day data reporting requirement for billing RPM and [remote therapeutic monitoring] codes, as well as other restrictive billing conditions," the organizations said.

While ATA and ATA Action called CMS's recent addition of 13 new codes to the Medicare Telehealth Services in the proposed fee schedule for 2025 "a step forward," they are asking the agency to make further additions that will maintain "consistent and appropriate access" to essential patient care services.

For example, the removal of radiation-treatment management from the Medicare Telehealth Services list "could inadvertently disrupt patient care and access to vital services," ATA and ATA Action said.

THE LARGER TREND

While CMS continues to generally add more reimbursement codes – such as for cancer patient navigation services and dental care – to the overall physician fee schedule each year, provider groups were concerned when the Final Rule for 2024 reduced their payment amounts by 1.25% compared to those of 2023.

Health tech leaders saw expanded reimbursement in the 2023 schedule as a surge of support for telehealth innovation under the Medicare program.

The commitment offered the freedom to innovate and provide better and more equitable care, Dr. Robert Murry, chief medical officer of NextGen Healthcare and a practicing family physician, told Healthcare IT News at the time.

But by November, the agency's reduced reimbursements soured providers' enthusiasm.

Dr. Jesse Ehrenfeld, president of the American Medical Association, said in November that the Medicare physician payment schedule was "an unfortunate continuation of a two-decade march in making Medicare unsustainable for patients and physicians."

ON THE RECORD

"We are concerned that reductions in payment rates under the fee schedule could inadvertently disincentivize the adoption of telehealth and hinder providers' ability to adequately invest in the necessary technological infrastructure or incorporate it into their workflow," ATA and ATA Action said in their comments. "Fair payment should consider these varying factors."

Andrea Fox is senior editor of Healthcare IT News.
Email: afox@himss.org
Healthcare IT News is a HIMSS Media publication.