In the letter, CHA:
- Encourages CMS to expand and make permanent several regulatory flexibilities the agency adopted in response to the COVID-19 pandemic. These regulatory flexibilities greatly increased the use of telehealth and other communications technology-based services, and CMS is urged to ensure that telehealth services are adequately reimbursed at levels that recognize their important place in the health care delivery system.
- Supports making permanent policies to increase flexibilities for teaching physicians and residents currently allowed for the duration of the public health emergency.
- Strongly supports delaying clinical laboratory reporting requirements until 2022 and the extended phase-in of payment cuts.
- Urges CMS to consider alternatives that would delay or phase-in significant redistributive impacts of the proposed revalued office/outpatient evaluation and management visit and related codes.
Comments were due to CMS on Oct. 5.