Expansion of the face-to-face encounter criteria to include audio-only telehealth for risk adjusted payments

America’s Physician Groups (APG) applauds the Centers for Medicare & Medicaid Services (CMS) for its recent announcement that has allowed physicians to utilize telehealth services for risk adjustment during the COVID-19 public health emergency. Allowing physician groups to treat Medicare Advantage beneficiaries wherever they are located during the nationwide shelter-in-place orders enables us to provide the necessary care for combating the ongoing pandemic while
being appropriately recognized for that care.

Summary of APG’s Recommendation

  • Extend eligibility for risk adjustment payment to telehealth services conducting through audio-only technology such as landlines or non-smartphone cellular technology

Under the guidance CMS recently issued, organizations that submit diagnoses for risk-adjusted payment based on telehealth visits may do so only if the visits involve a face-to-face encounter that uses interactive audio and video telecommunications system such as a video-equipped smartphone. We are writing to request that CMS consider extending eligibility for risk adjustment payment to telehealth services conducted solely through audio-only technology such as landlines.

Many senior patients do not have access to the expensive technology required to allow us to qualify for HCC coding under your guidance. We also have patients that have expressed difficulty in navigating the video technology included on video-equipped smartphones and similar devices.

In addition, telehealth services hold particular importance for patients living in rural areas of the country for whom travel has always been difficult, even before the adoption of widespread social distancing. These areas usually do not have widespread access to broadband internet service making compliance with the video requirement for a face-to-face encounter an impossible lift for these patients that need these services the most. As CMS has established multiple initiatives in support of rural healthcare in the wake of the COVID-19 pandemic, removing the video requirement for risk-adjusted payment of telehealth services will serve to reinforce the importance of reaching patients in these underserved areas and ensure that they receive all necessary care.

Delivering care during this time of crisis is imperative, and reaching as many patients as possible in locations that are convenient for them is the best way to ensure treatment is being given. Barriers that discourage patient participation in telehealth or put organizations in greater financial peril will prevent patients from receiving necessary care. We ask CMS to ensure that providers are reimbursed for all the services rendered during this crisis so that as many patients maybe treated as possible.

Thank you for your attention to our appeal. We look forward to continuing to work with you throughout this process. Please feel free to contact Valinda Rutledge, Senior Vice President, Federal Affairs, (vrutledge@apg.org) if you have any questions or if America’s Physician Groups can provide any assistance as you consider these issues.

Click here to download the letter.