HIMSS Supports Proposed Extensions to Telehealth Coverage in CMS Physician Fee Schedule Proposed Rule

Patient on a telehealth call with medical provider

HIMSS, a global advocate for digital health transformation, supports a proposed extension of coverage for telehealth services through Dec. 31, 2024.

The reimbursement, at the non-facility rate, was originally scheduled to cease when the federal government ended the COVID-19 public health emergency on May 11, 2023.

More than 150 million people live in federally designated mental health professional shortage areas, and there has been a significant increase in mental health challenges across the world since the beginning of pandemic. HIMSS wrote in public comments submitted to the Centers for Medicare and Medicaid Services on Sept. 11 that removing additional barriers for telehealth services for healthcare providers and patients will have an immediate positive impact on the lives of countless Americans.

The proposed extension allows providers to continue to offer telehealth services while Congress identifies a long-term solution.

CMS published the proposed Medicare and Medicaid Programs; CY 2024 Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment and Coverage Policies; Medicare Shared Savings Program Requirements; Medicare Advantage; Medicare and Medicaid Provider and Supplier Enrollment Policies; and Basic Health Program, on Aug. 12.

The proposed rule included:

  • Proposal to reimburse providers for social determinants of health voluntary screenings for Medicare and Medicare Advantage beneficiaries
  • Proposal to adopt any changes finalized by the Office of the National Coordinator (ONC) certification program into future iterations of the Promoting Interoperability Program requirements for the Quality Payment Program (QPP) and the Medicare Shared Savings Program (MSSP), without additional rulemaking or public comment opportunities
  • Proposal to add one new electronic clinical quality measure to the QPP measure set
  • Pause the Appropriate Use Criteria (AUC) program requirements until problems with real time claims data processing can be addressed

HIMSS explained several key points in its response.

With regard to changing certification requirements, HIMSS recommends that CMS allow providers enough time to successfully complete the extensive work required to implement and test the certification changes across their practice, while ensuring quality, safety and patient privacy are not compromised. HIMSS has recommended this will take at least 18 months following the final publication of new certification requirements by ONC, and HIMSS recommends CMS follow the same timeline. HIMSS does not want healthcare providers acting in good faith to be penalized because of insufficient implementation time because of delays associated with standards development, vendor timelines and staffing shortages impacting the healthcare community.

HIMSS supports the pause in the Appropriate Use Criteria program and called for CMS to improve the usability of the AUC clinical decision support mechanisms (CDSMs) to reduce clicks for providers.

HIMSS supports the extension of the telehealth program and called specifically on the importance of providing mental health services via telehealth for patients who do not have face-to-face access to mental health interventions. In addition, HIMSS supports extending the allowance for virtual supervision of resident clinicians in care settings.

HIMSS supports the proposal to reimburse providers for SDOH screenings and called on CMS to clarify the level of licensure required to administer SDOH screenings.

HIMSS called on CMS to publish real-world field-testing data, including the vendors supporting testing sites and the number of testing sites, whenever proposing the inclusion of a new electronic clinical quality measure in the QPP and MSSP measure sets. HIMSS also called on CMS to adopt innovative strategies to incentivize end-user participation in testing programs, as small practices, safety net organizations and not-for-profit care delivery sites often can’t afford to expend the resources needed to participate in testing programs.

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