CHA submitted comments on the calendar year (CY) 2022 physician fee schedule proposed rule.
In the letter, CHA:
- Urges CMS to work with Congress to address significant payment reductions to the proposed conversion factor and physician payments
- Urges CMS to continue to support the expansion of telehealth by finalizing proposals to maintain Category 3 telehealth services until the end of CY 2023 and adopt the same policy for telehealth services added to the Medicare telehealth list for the duration of the COVID-19 public health emergency, but not as Category 3 services.
- Strongly supports waiving geographic site restrictions and adding the patient’s home as an originating site for mental health services provided via telehealth. CHA also urges CMS to consider revising its proposed policies on the interval of required in-person visits and clarify that patients can be seen in-person by clinicians in the same group as the practitioner who provides the telehealth service.
- Strongly supports CMS’ proposed modification to the definition of “interactive telecommunications system” to include audio-only communications for mental health services and urges CMS to apply this definition to additional services, such as evaluation and management (E/M) services as allowed during the COVID-19 public health emergency
- Strongly supports a delay in the payment penalty phase of the Appropriate Use Criteria program and urges CMS to reconsider proposals to repurpose certain modifiers
- Urges CMS to reconsider several proposals related to E/M services, including proposals related to split billing and critical care services
- Urges CMS to clarify several proposals related to the rural health clinic (RHC) per visit limit as established by the Consolidated Appropriations Act of 2021 (CAA) and provide additional flexibilities for provider-based RHCs that were under development prior to the CAA’s passage
- Generally supports proposed changes to the Medicare Shared Savings Program and provides feedback in response to the agency’s requests for information related to benchmarking and risk adjustment
CHA thanks members for their feedback, which helped inform comments.