On December 31, 2018, HIMSS and the Personal Connected Health Alliance (PCHAlliance) joined together in responding to the Centers for Medicare and Medicaid Services (CMS), Medicare and Medicaid Programs; Policy and Technical Changes to the Medicare Advantage, Medicare Prescription Drug Benefit, Program of All-inclusive Care for the Elderly (PACE), Medicaid Fee-For-Service, and Medicaid Managed Care Programs for Years 2020 and 2021 proposed rule. The comments in this letter to Administrator Seema Verma focused on the “Requirements for Medicare Advantage Plans Offering Additional Telehealth Benefits.”
HIMSS and PCHAlliance appreciates CMS’ leadership and diligent work to modernize Medicare and advance connected health for Medicare beneficiaries. They were heartened to read CMS’ analysis of the impact of “additional telehealth benefits” as it wisely includes the documented savings associated with reduced travel time, more efficient care delivery, and, acknowledges the real potential for connected care to prevent disease progression and promote health. They support the proposed rule to implement Medicare Advantage (MA) additional telehealth service.
HIMSS and PCHAlliance note that allowing MA plans to cover any Part B benefit through both electronic exchange and in-person visits, when both means of delivering the Part B benefit are clinically appropriate. The inclusion of electronic exchange modernizes the MA program in a manner that allows the provision of evidence-based, effective care in a technology neutral manner.
The proposal for MA plans to determine on an annual basis which services they may cover as “additional telehealth benefits”, is much appreciate by HIMSS and PCHAlliance. This medical review process already in place offers an efficient and effective means to identify evidence-based services, tools, and technologies in a flexible and technology neutral manner. It is essential to take a flexible approach that allows for adoption of evidence-based innovation, particularly those that improve patient engagement, quality of care, and reduce costs.
HIMSS and PCHAlliance also urge CMS to use only the MA plan annual determination and medical review to define the types of items and services to be included as additional telehealth benefits.
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