Letter Requesting Risk Adjustment for Audio-Only Telehealth Services

April 20, 2020

The Honorable Alex Azar
Department of Health and Human Services
Hubert H. Humphrey Building
200 Independence Avenue SW
Washington, DC 20201

Ms. Seema Verma
Centers for Medicare & Medicaid Services
Hubert H. Humphrey Building
200 Independence Avenue SW, Room 445-G
Washington, DC 20201

Dear Secretary Azar and Administrator Verma:

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.

About America’s Physician Groups

APG is a national professional association representing over 300 physician groups that employ or contract with approximately 195,000 physicians that provide care for nearly 45 million patients. Our tagline, “Taking Responsibility for America’s Health,” represents our members’ vision to move away from the antiquated fee-for-service (FFS) reimbursement system where clinicians are paid “per click” for each service rendered rather than on the outcomes of the care provided. Our preferred model of accountable, risk based, and coordinated care avoids incentives for the high utilization associated with FFS reimbursement. APG is committed to Medicare Advantage and the flexible, affordable, and efficient care it provides for seniors. APG member organizations are working diligently to rise to the challenge presented by the COVID19 pandemic. We are focused on the transition of many patient visits to telehealth as a best practice in slowing the spread of the coronavirus and keeping patients safe.

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 an 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 may be 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.


Donald H. Crane
President and CEO
America’s Physician Groups

Please click here to download a copy of the letter.