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2020-04-30 CMS Telehealth and Home Admin

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CSRO Comments on CMS Telehealth and Home Administration

Posted: April 30, 2020


In response to rapidly evolving circumstances surrounding the COVID-19 pandemic, CMS has made numerous interim revisions to its policies. These changes are designed to streamline patient access to care during the pandemic and large scale social distancing. Although the changes have largely taken effect, CMS has still provided the opportunity for stakeholders to issue comments. We would like to thank our state society members that lent their support to our comments.

While CSRO is supportive of many of the new telehealth flexibilities, and believes that they should be extended beyond the current crisis, there are improvements that CMS could make to the program. For example the video requirement for furnishing telehealth E/M services has proven difficult to implement for beneficiaries who lack the necessary video equipment or refuse to appear on camera. To improve access, CSRO suggests that CMS could increase reimbursement for telephone E/M services.

CSRO also took the opportunity to comment on new revisions to CMS’s home administration policies for Part B drugs. CMS’s revisions allow for an expansion of home administration, a practice that CSRO has long opposed. While CSRO is appreciative of CMS’s desire to ensure continuity of care, it is unclear that provider administration of these drugs has been substantially disrupted.

In order to gauge whether the concern driving this change is warranted, CSRO is conducting a survey of rheumatologists. We encourage you to take the survey so that we may develop a robust dataset.

Read the Full Comments

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