More than 100 medical groups and independent practice associations are urging the Centers for Medicare & Medicaid Services (CMS) to extend the eligibility for risk adjustment payment to audio-only telehealth services, such as talking to patients over landline phones.
During the ongoing COVID-19 pandemic, the American Medical Group Association (AMGA) and other physician groups want audio-only visits to satisfy CMS' face-to-face requirement to gather diagnosis information for risk adjustment and care coordination purposes.
AMGA and 100 other physician groups issued a letter (PDF) this week to Department of Health and Human Services (HHS) Secretary Alex Azar and CMS Administrator Seema Verma urging them to reduce the regulatory burden on physician practices by supporting audio-only telehealth services.
In the letter, AMGA praised CMS for supporting telehealth during the COVID-19 pandemic but said the agency needs to go further. The requirement that telehealth services be provided via live, audiovisual telecommunications remains a significant barrier for patients and physicians during the pandemic, the groups said.
In many instances, patients only have a traditional audio phone call available.
In a bid to help support practices during the COVID-19 pandemic, CMS last month issued sweeping temporary changes and agreed to pay for virtual visits at the same rate as in-person visits while the coronavirus emergency remains in effect. As of March 30, CMS is now allowing more than 80 additional services through telehealth.
Among the changes was the decision to begin paying for visits that take place by audio telephone only. Previously, CMS had agreed to pay for virtual visits only if physicians used both audio and video feeds via traditional telehealth.
But physicians have complained that reimbursement is lower for audio-only telehealth visits compared to audio and visual telehealth visits. And, under current CMS rules, any diagnosis made during an audio-only visit with a patient cannot be used for risk adjustment purposes.
This restriction undermines both the financial stability of physician practices and those practices' patient care goals, according to the AMGA.
"The agency’s requirement that telehealth services be provided via live, audiovisual telecommunications remains a significant barrier for patients and physicians during the pandemic. A major component of telehealth services are audio-based services, or care provided over the telephone, which remains a straightforward and preferable alternative for many patients and physicians," AMGA and the medical groups said.
Patients may not have access to the technology or broadband service necessary to receive care through video-based modalities. Elderly senior or frail patients may not be comfortable using video services or may have physical limitations that prevent them from doing so.
Many senior citizens who are isolated and sheltered at home rely on children and grandchildren to access technology and don't know how to connect via video visits, industry stakeholders say.
"For these patients, the choice is not between a video visit and a phone visit – it is the choice between an audio visit or no visit. If they are not able to communicate with their physician, the risks are significant," AMGA wrote in the letter.
"Too many Americans lack the technology or broadband service necessary to receive care through video-based modalities,” said Jerry Penso, M.D., president and CEO of AMGA. “Recognizing this need, clinicians have continued to provide care for these populations during the pandemic, using only audio-based services, including landline phones. This care is vital to many patients who are unable to access audiovisual technology.”
Last week, an analyst with CMS confirmed that the agency is considering expanding reimbursement for audio-only telehealth visits.
During a webinar sponsored by the eHealth Initiative, Emily Yoder, an analyst in CMS' Division of Practitioner Services, said there are currently audio-only telephone E/M codes that provide some reimbursement for clinicians but not at the same level as an office visit.
In late March, Congress passed the Coronavirus Aid, Relief, and Economic Security (CARES) Act, a $2 trillion relief package. That legislation gave HHS the authority to grant waivers for easing some reimbursement restrictions, Yoder said.
"Through that CARES Act authority, HHS is able to waive video-only requirements and we are deciding whether to pursue that. We are considering how best to deploy that additional authority," Yoder said.
Yoder also hinted that CMS is looking to make permanent policy changes to support physicians as they transition to virtual care.
"These waiver changes are tied to the pandemic. However, we are also considering through the regular rule-making process what things we want to adopt on a regular basis," she said. "There are restrictions on where a patient has to be and that is in the statute, so Congress has to make that decision and implement changes through legislation."
Even as restrictions ease and patients begin to slowly return to in-person care settings, medical groups will face tremendous backlogs of unmet medical needs, AMGA and other medical groups wrote in the letter.
"For these reasons, we will continue to rely on both audio and video-based technologies to enhance access and safely care for our patients throughout this extended COVID-19 pandemic and recovery period. Therefore, we ask that you expand your recent memo to clarify that services provided by audio-only will count for risk adjustment purposes," the groups wrote to Verma and Azar.