Expansion to telemedicine coverage for Medicare beneficiaries recommended by the Centers for Medicare & Medicaid Services in its proposed update to the Medicare Physician Fee Schedule for 2015 generally was praised in comments recently submitted by industry stakeholders, including the American Telemedicine Association (ATA) and the American Hospital Association (AHA).
ATA CEO Jonathan Linkous, in a letter sent to CMS Administrator Marilyn Tavenner, said his organization "strongly supports" the recommendations, which include proposed coverage of annual wellness visits and psychotherapy. He added that ATA "appreciates CMS making explicit that two CPT codes for computer-based psychological testing are payable in the same way as other physicians' services, and not as telehealth services with accompanying severe restrictions."
Linda Fishman, senior vice president of public policy analysis and development at AHA, said her organization was "especially pleased" to see "certain behavioral health services" receive more attention.
"Covering these telehealth services will expand access to care for Medicare beneficiaries, particularly in rural areas," Fishman said. "We believe more services could be effectively and efficiently furnished using telehealth and we encourage the agency to consider adding other services on its own initiative in future rulemaking."
American Medical Association CEO James Madara, in his letter to Tavenner, said that while AMA, too, supports the expanded coverage, it also "urges" the consideration of other factors for telemedicine services.
"For example, the AMA urges CMS to prioritize coverage of telemedicine services that include care coordination with the patient's medical home and/or existing treating physicians," Madara said. "This includes at a minimum, identifying the patient's existing medical home and treating physician and providing to the latter a copy of the medical record."
A telemedicine policy adopted by AMA in June calls for a "valid patient-physician relationship" by way of an in-person consultation for services that otherwise would require face-to-face examinations before continuing treatment via telemedicine. The policy also recommends that doctors delivering telemedicine be licensed in the state where a patient is receiving treatment.
In a joint letter to Tavenner, Russell Branzell, president and CEO of the College of Healthcare Information Management Executives, and Richard Rydell, CEO of the Association of Medical Directors of Information Systems, also applauded the proposed expansion, but said CMS should be bolder in its action.
"Namely, we believe CMS should reconsider its definition of originating site, both the geographic boundaries and the eligibility process," Branzell and Rydell said. "[T]he current definition still limits access to telemedicine services for patients, who may be unable to commute for various reasons, in urban areas." The CEOs added that CMS should consider patient homes and first-responder vehicles to be originating sites.
Branzell and Rydell also ask CMS to revisit its "store and forward regulation."
"Patient-generated health data is routinely highlighted as an enabler of engaged patient-centric models of healthcare," they said. "[A]dvancements in technology beyond simple, two-way communication have eclipsed the need to preclude store and forward limitations."
To learn more:
- here's the ATA's letter (.pdf)
- check out the AHA's comments (.pdf)
- read the AMA's letter (.pdf)
- check out the comments from CHIME and AMDIS (.pdf)