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  • Washington Highlights

    AAMC Comments on RFI Seeking to Promote Efficiency and Advance Equity at CMS


    Ki Stewart, Senior Policy and Regulatory Analyst
    For Media Inquiries

    The AAMC submitted comments to the Centers for Medicare & Medicaid Services (CMS) on Nov. 4 in response to the “Make Your Voices Heard  request for information on how to promote efficiency, reduce burden, and advance equity within CMS programs.

    The association made several recommendations to address current challenges utilizing health care services across CMS programs. These included suggesting that the CMS invest in the physician workforce in all specialties by increasing the number of Medicare-supported graduate medical education positions, increasing Medicaid and Medicare reimbursement rates for behavioral health providers, working with Congress to eliminate the in-person visit requirement for telehealth, and establishing sufficient payment and network adequacy to support maternal care under its programs. The letter also recommended the agency take any steps necessary to ensure that providers can continue to offer reproductive health care services to patients without the threat of civil or criminal liability and that residents and students receive training in order to provide medically necessary care. 

    The AAMC also commented on health care workers’ needs, noting that the CMS should support efforts in Congress to prevent the 4.42% physician payment cut and waive the 4% statutory pay-as-you-go reduction. [refer to Washington Highlights, Oct. 7].To reduce administrative burden and burnout, the AAMC urged the agency to address electronic health records usability, documentation requirements, and prior authorization. The association also recommended that the agency use levers to incentivize states to increase Medicaid reimbursement rates in order to ensure equitable access to care for Medicaid patients.

    The comments included several recommendations to advance health equity, including suggesting that the CMS offer incentives for providers to improve data collection, collaborate with external participants and other federal policymakers to evaluate and prevent potential bias in technology, strengthen its oversight of the Medicare Advantage (MA) program, and issue new guidance on appropriate use of clinical criteria in medical necessity reviews and Medicare coverage rules for MA plans.

    Regarding COVID-19 waivers and flexibilities, the AAMC encouraged the CMS to work with Congress to permanently eliminate the geographic site requirements and allow the home to be an originating site for telehealth services. The comments also suggested that the agency work with Congress to permanently allow payment for telehealth services across state lines, allow payment for audio-only technology, expand the definition of eligible telehealth providers, and allow payment for telehealth services furnished by Federally Qualified Health Centers and Rural Health Clinics. Additionally, the comments recommended that the CMS work with Congress to support the Hospital Inpatient Services Modernization Act (H.R. 7053, S. 3792) that would extend the current Acute Hospital Care at Home waiver for two years after the end of the COVID-19 public health emergency [refer to Washington Highlights, March 11].