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C-TAC supported many of the CMS flexibilities designed to respond to the COVID-19 pandemic and advocated for making some of them permanent, in a letter responding to a CMS interim final rule this week.

Our response addressed many areas that serve those with serious illness including:

Payment for Medicare Telehealth Services:
We supported the variety of changes related to telehealth, including allowing telehealth to be received outside of a clinical setting, such as in a person’s home. Because of the continuing benefits of and need for telehealth services for those with serious illness, we recommend that this change be made permanent.

Telehealth Modalities:
C-TAC supported the exception allowing “interactive telecommunications system” to mean equipment that includes, at least, audio and video tools permitting two-way, real-time communication such as Skype, Zoom and FaceTime. These are useful during the COVID-19 pandemic and will also be needed on an ongoing basis.

We also pointed out that some beneficiaries lack access to smart phones, computers and even broadband or cellphone services and recommended that this equity issue be addressed by allowing audio—only telehealth services permanently.

Beneficiary Cost-Sharing:
We supported allowing providers to reduce or waive any cost-sharing obligations that federal health care program beneficiaries may owe for telehealth services, due to financial strain caused by the COVID-19 pandemic. We also recommended removing the current copays for the advance care planning billing codes and re-categorizing them as preventative services.

Communication Technology-Based Services:
We supported providing telehealth to both new and established patients and recommended this be made permanent. While real-life interactions between providers and new patients is preferable, this emergency has taught us that’s not always possible.

Use of Telehealth Under the Medicare Hospice Benefit:
C-TAC strongly supported amending the hospice regulations to let hospices provide services via telehealth for routine home care when appropriate. This is a critical need during this emergency, but we believe it also makes sense to allow some home care to be delivered via telehealth on a permanent basis or at least in other emergencies.

We supported the guidance that a face-to-face visit solely for the purpose of recertification for Medicare hospices services could be performed via telehealth during the COVID-19 public health emergency and recommended that this remote certification be made permanent as it will benefit patients beyond the pandemic.

Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs):
C-TAC supported the expansion of telehealth provided by RHCs and FQHCs during the COVID-19 public health emergency. We also supported that all telehealth will also be available to new patients in those facilities.

Special Requirement for Psychiatric Hospitals:
We supported the clarification that would allow non-physician practitioners (NPPs) to practice to the full extent of their license and certifications. During and after this pandemic, we will need all NPPs available to provide care for those with serious illness.

Telehealth flexibilities and other pressing issues affecting the serious illness care field will be topics of discussion during the C-TAC Policy Forum, from 1-4 PM ET on June 24. This free, virtual event will gather leaders and advocates to share the latest policy insights and analysis to support those on the frontlines of the pandemic. To learn more and register now, click here.

For more information about C-TAC’s legislative and regulatory efforts, please contact Policy & Advocacy Manager Davis Baird at DBaird@theCTAC.org.

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