HIMSS and PCHAlliance Reaffirm the Need for a Transition Plan from the PHE Telehealth Waivers

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On Monday, June 1, HIMSS and the Personal Connected Health Alliance provided written comments to the Centers for Medicare & Medicaid Services (CMS) on the Medicare and Medicaid Programs; Policy and Regulatory Revisions in Response to the COVID–19 Public Health Emergency Interim Final Regulation that focused on the need to create and communicate a transition plan for the telehealth and communication-based technology services waivers that were instituted as part of the COVID-19 Public Health Emergency (PHE).

HIMSS and PCHAlliance expressed concern that when the PHE finally ends, the community will require a transition from the telehealth waivers, rather than a sudden termination, to ensure stability, embed resilience and develop a modern, value-based, health delivery system.

Our organizations advocated for the statutory authority to allow for waivers of the Section 1834(m) restrictions on telehealth in the event of a health emergency. Now, our focus has shifted to creating a long-range, community-wide transition plan for the telehealth waivers post-PHE.

Our comment letter to CMS emphasized the critical role that digital health plays in supporting healthcare resilience, transformation, and modernization during times of emergency and disruption. This has been well-documented from case studies of care delivery after Hurricane Katrina, and now, it includes the work that HIMSS has underway to advocate for Immediate State and Local Strategies for a Public Health Emergency that discuss expanding telehealth services as a key component of a COVID-19 preparedness and response strategy.

HIMSS and PCHAlliance want to ensure that CMS creates a viable post-PHE transition plan that allows providers the opportunity to safely care for all patients, as well as have access to all available treatments, including digital health solutions. Overall, we recommended CMS provide communication that reassures the provider community that there will be a transition for connected care, and a commitment to developing a framework focused on advancing value-based, patient-centered health care to guide the phasing down of some waivers and the transition to permanence of others.

Ultimately, we want retention of the waivers while a principle-based, time-defined process to evaluate modifications and permanence of the waivers occurs.

Moreover, specific to Medicare and Medicaid, we offered to work with CMS to collect and review data that relate to both the efficacy from telehealth and provide a sustainable financial model for providers, while addressing the skepticism within the patient community that their out-of-pocket costs should be the same for face-to-face and telehealth visits. As many providers have made the short-term investment in telehealth, we want to ensure that the financial business model continues to incentivize them to offer telehealth services.

HIMSS and PCHAlliance are very interested in working with CMS to find a path forward that ensures greater parity for providers and proper incentives for patients in telehealth care delivery.

HIMSS Government Relations

The HIMSS policy team works closely with the U.S. Congress, federal decision makers, state legislatures and governments, and other organizations to recommend policy, and legislative and regulatory solutions to improve health through information and technology.

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