URAC submitted comments to the Centers for Medicare and Medicaid Services (CMS) on the agency’s proposed Medicare physician fee schedule for the 2021 calendar year.
The schedule is updated annually. This year, it was one of the most anticipated regulatory documents in recent memory for health care entities as the document indicates how CMS proposes to manage services and reimbursement during and beyond the current public health emergency (PHE). The proposed rule made several notable changes to existing Medicare policy, including the creation of new payment rates for administering immunizations that reflects their importance in response to the COVID-19 pandemic.
CMS also importantly reiterated that pharmacists may continue to bill for services incidental to physicians’ services. This reaffirmation of the vital role pharmacists play on the front lines of the COVID-19 pandemic response demonstrates the key position pharmacists will play in the eventual rollout of a COVID-19 vaccine.
Perhaps the area of greatest potential change proposed in the 2021 fee schedule references the expansion of digital health in Medicare. CMS proposed expanding payment for telehealth services by adding 22 new billing codes. CMS also proposed creating a new temporary category of codes for services that Medicare will cover during COVID-19.
While related, CMS handles telehealth and remote physiologic monitoring (RPM) separately, because of statutory requirements and different clinical considerations. Therefore, over the past several years, CMS expanded RPM services reimbursement more rapidly than they did for telehealth. In 2019 and 2020, for billing purposes, CMS created new codes for RPM services and changed guidelines for services delivered under general supervision. CMS also temporarily removed several long-standing provisions to expand utilization of RPM services and proposed continuing the removal of these provisions during the PHE. However, CMS also proposed several permanent changes to RPM reimbursement that key industry stakeholders fear may be barriers to long-term utilization of technology to support patient care. Top concerns expressed by some stakeholders is the requirement of an existing patient-physician relationship prior to deployment of RPM services and limits on how often a provider can bill for certain RPM services per patient during a 30-day period.
URAC accreditation does not address payment parameters for Medicare or any other public or private programs. However, URAC supports policies that expand patient access to safe and effective digital health technologies. URAC’s comments regarding the new fee schedule outline our support and highlight the need for CMS to consider a framework for long-term oversight of new technologies to supplement and improve patient care.
Given the overnight explosion of telehealth adoption due to the pandemic, many digital programs may be considered immature. While the vast majority of providers are striving to adopt telehealth in appropriate ways, the present environment could allow for unscrupulous individuals to take advantage of the reduced oversight from federal officials. URAC believes the current approach to program integrity needs to be expanded to accommodate increased telehealth adoption. We also believe the appropriate oversight function should be similar to the standards that providers and facilities must adhere to for access to Medicare, Medicaid, and commercial insurance reimbursement. Additionally, we believe that this can be accommodated through provider enrollment and deemed programs to ensure no additional administrative barriers are created for hospitals, surgical centers, providers, home health agencies, and suppliers. Finally, we believe that there should be a requirement for providers to adhere to best practices in the following areas: patient consent and disclosure; data privacy and security; credentialing; clinical guidelines and oversight; e-prescribing; and hardware/software functionality.
The final Medicare physician fee schedule is expected in November.
