Physician’s Advocacy with the CMS Telehealth Guidelines

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Many physicians would like CMS to keep the updated telehealth policies. Here is a summary of their comments.

In light of the pandemic, CMS has significantly changed its telehealth policies. Geographic and HIPAA restrictions have been removed, numerous new telehealth codes have been created, and doctors may waive cost-sharing for patients via telehealth. Public’s enthusiasm for reforms, most of these changes are expected to reverse once the epidemic has been officially recognized as over.

In Some Way or Another, the Phenomenon Discussed is Related to Nature.

According to CMS data, 45% of primary care visits were conducted via telehealth in mid-April. Patients now realize the advantages of seeing their physicians remotely. It has established a new norm in which patients have discovered the advantages of seeing their doctors remotely.

Telehealth regulations are set to revert by the end of the public health emergency (PHE). Considering this sudden reversal, it would jeopardize the significant progress in improving healthcare delivery to U.S. patients. We want to make the following policy recommendations, therefore:

  • CMS should keep updating its outlook on telehealth
  • Geographic restriction waivers should become permanent
  • CMS should allow doctors to continue to have the ability to lower or eliminate cost-sharing for patients’ telehealth.
  • CMS should return to HIPAA-compliant technology requirements
  • The Category 3 category should include occupational and physical therapy services.

CMS Should Maintain its Overall Telehealth Outlook

Due to the global pandemic, CMS has had to reexamine aged notions of telehealth. Telehealth was initially considered a possible treatment option, but CMS restricted telehealth compensation to rural patients with no alternatives. Patients had to find a doctor who would work for bargain telehealth fees and numerous other limitations. It hindered telehealth use and made it difficult to function.

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We believe that CMS Should Maintain its Current Telehealth Approach for the Following Reasons:

Eliminating the patient’s time spent commuting and waiting for physicians reduces the opportunity cost of care. In a study published in the American Journal of Managed Care, patients spend an average of over an hour and a half driving to and waiting for their appointments for a nationwide opportunity cost of $52 billion each year.

According to the CDC, one-third of patients aged 18-64 reported that the reason for their most recent emergency department visit was not due to the “seriousness of the medical problem.” Telehealth can meet patients’ needs and save medical resources by reducing the exorbitant costs associated with the typical emergency room visit. If fewer patients used the emergency room for less severe concerns, emergency departments could provide more intensive care for more urgent cases.

According to CMS, preventive care is the most significant component of any healthcare system. The seven major chronic conditions mentioned by CMS, including heart disease, cancer, and diabetes, are among the most deadly, and they can be prevented. People can utilize telehealth, a convenient and safe form of preventative care that does not require much time to access. Telehealth can be used to improve medication adherence, clinical outcomes, and dietary outcomes, 

Telehealth can help prevent the spread of infectious diseases. This is the most important reason why telehealth is so essential. During the COVID-19 pandemic, researchers demonstrated that this reason is the most important. Healthcare-associated infections have been a severe danger for patients despite the introduction of safety procedures. Today, patients are even more worried about contracting a lethal injection at a healthcare facility. According to the U.S. Department of Health and Human Services, “With about 1 in 25 hospitalized patients suffering from an infection associated with hospitalization, these infections lead to tens of thousands of fatalities and billions of dollars in costs annually.”

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Geographic Restriction Waivers Should be Permanent

When these guidelines were formulated, telehealth technology was in its infancy. Despite the technological constraints, policymakers recognized that telehealth was the only feasible option for many rural patients. Despite technical shortcomings, policymakers knew that the world had changed and telehealth was the best alternative for patients. As a result, healthcare delivery has become more advanced, inexpensive, and safe through telehealth technology. Consequently, we advocate for the removal of geographic restrictions.

Giving Doctors the Flexibility to Reduce or Waive Cost-Sharing for Telehealth Patients is What CMS Should do

Sending a patient to the doctor’s office or hospital is costly, especially for those who cannot afford the cost. Telehealth is one of the most cost-effective methods of providing care to patients. Allowing doctors to waive or reduce cost-sharing would result in potential financial savings and increased demand for telehealth services. It would decrease the number of patients visiting an in-person hospital or clinic and the spread of disease, as in-person resources would be depleted.

CMS Should Require HIPAA-Compliant Technology

CMS’ decision to waive various HIPAA regulations was a wise choice during the pandemic. This timely decision assisted the country as physicians made the sudden switch from in-person care to telehealth. However, physicians now face a severe risk of losing patients due to potential security issues. The longer HIPAA requirements are waived, the further patient information is jeopardized. Particularly during a pandemic when hackers have been especially active. For this reason, we strongly advise CMS to transition to its previous policies concerning HIPAA-compliant technology.

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Physical and Occupational Therapy Services Should be Covered Under Category 3

We stand behind the new telehealth CPT codes CMS is trying out as Category 3. We completely endorse the CPT codes CMS has picked to be part of Category 3, and we believe CMS will make them permanent. We commend CMS for finding services that meet the needs of Category 3, but we also recommend adding the following physical and occupational therapy CPT codes: 92521-92524, 92507, 97161-97168, 97110, 97112, 97116, 97535, 97760-97761, 99217-99226. CMS should try out these CPT codes and decide whether or not they are as long-term feasible as telehealth services.


We appreciate the opportunity to comment on these guidelines and recommend the above suggestions as telehealth is rapidly incorporated into the U.S. healthcare system.

Telehealth has the potential to save money, extend access to care, preserve medical resources, and reduce disease spread in our community. In accordance with the expansion and implementation of telehealth services at CMS, physicians will finally have everything they need to treat all of their patients.

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