May 18, 2020

APMA submitted comments to CMS in response to CMS’ interim final rule on flexibilities for physicians and other providers during the public health emergency (PHE). APMA thanked CMS for finalizing provisions APMA requested previously, including: 

• increasing payment for audio-only telephone E/M services (CPT 99441–99443) by cross-walking with the work RVUs and direct practice expense inputs for CPT 99212–99214, on an interim basis for the duration of the COVID-19 PHE; allowing hospital outpatient services to be furnished in temporary expansion locations of a hospital (including a patient’s home); and
• providing clarity regarding use of time for level selection for office/outpatient E/M services furnished using telehealth.

APMA took the opportunity to inform CMS of the vital services podiatrists are delivering remotely to their patients using telehealth, virtual check-in, telephone E/M, and online digital E/M. APMA urged CMS to continue access to these services with appropriate reimbursement even after the current emergency abates. 

While APMA thanked CMS for continued waivers and flexibilties, we also requested additional relief to alleviate costs associated with regulatory burdens from the Appropriate Use Criteria program and MIPS reporting requirements. 

Learn more about APMA’s COVID-19-related advocacy initiatives on APMA’s COVID-19 resource page. 

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