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AAMC Submits Letter to CMS on Future of Telehealth Flexibilities

May 15, 2020

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CONTACTS
Gayle Lee, Director, Physician Payment & Quality
Kate Ogden, MPH, Policy & Regulatory Analyst, Physician Payment & Quality

The AAMC sent a letter on May 14 to Centers for Medicare and Medicaid Services (CMS) Administrator Seema Verma urging the administration and Congress to make changes to legislation and regulations to make permanent some of the telehealth waivers and flexibilities that were put in place during the COVID-19 public health emergency (PHE).

In the letter, the AAMC thanked Administrator Verma for the actions CMS has taken during the COVID-19 pandemic to provide regulatory relief and flexibility specifically related to telehealth and other communication technology-based services, which have increased the ability of teaching hospitals and faculty physicians to expand care to patients.

 The AAMC specifically recommended the following:

  • Patient Location: Telehealth services should be covered for patients in any geographic location and at any site, including the patient’s home.
  • Payment: Providers should receive the same amount of Medicare Physician Fee Schedule payment as if the services had been provided in-person.
  • Hospital Payment: Hospitals should be allowed to bill a facility fee when the patient is an established patient of an outpatient department and receives a service at their home via telehealth.
  • Expansion of Telehealth Services: CMS shkarould expand the list of covered telehealth services to include services that were added during the pandemic. 
  • Relationship With Patient: Telehealth services should be allowed to be provided to new and established patients.
  • State Licensure/Practitioner Locations: Medicare and Medicaid requirements that physicians and nonphysician practitioners be licensed in the state where they are providing telehealth services should be removed to allow payment across state lines.
  • Residents: For evaluation and management (E/M) services, residents should be allowed to provide telehealth services if supervision requirements are met.
  • Telephone E/M Codes (99441-99443): The increased payment rates for these codes should be maintained to equal Medicare’s established in-person codes (99212-99214) to ensure that patients without advanced video-sharing capabilities can access care.  

The AAMC also requested additional flexibility for interprofessional consultations, including waiving the frequency limitations for these services and allowing the consultations for the same medical condition during the PHE. These changes could enable greater use of these services that minimize exposure risks of COVID-19 to all patients and their providers.

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