APMA Advocates for Members to HHS, CMS, and OASH in Comment Letters | News | APMA
APMA Advocates for Members to HHS, CMS, and OASH in Comment Letters

January 4, 2021

The end of 2020 was a busy time for member advocacy! APMA submitted comments on the following issues to HHS, CMS, and the Office of the Assistant Secretary for Health (OASH). Read the full comment letters at www.apma.org/CommentLetters

Reducing Provider, Patient Burden by Improving Prior Authorization Process and Promoting Patients’ Electronic Access to Health Information, and Other Policies (January 4)

In its comments to CMS, APMA highlighted its ongoing concerns related to increased use of prior authorization, which APMA believes will increase burden for providers and patients, as well as reduce access to care. APMA stressed the following:

  • CMS should require that patients have access to data that is easily available in plain language so they, along with their providers, make informed health-care decisions;
  • API implementation guides (IGs) should be used to the extent that IGs require uniformity and standardization in the sharing of updated provider directories; and
  • the Office of the National Coordinator for Health Information Technology (ONC) should add certification criteria to the ONC Health IT Certification Program so that health IT developers would be required to implement these functions within their EHRs.

Medicare Program, DMEPOS Policy Issues, and Level II HCPCS (January 3)

In its comments to HHS and CMS, APMA supported CMS’ proposal to establish fee schedule adjustment methodologies for Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) items and services furnished on or after April 1, 2021, or the date immediately following the duration of the Public Health Emergency (PHE) for COVID-19.

APMA also stressed the importance of transparency and less administrative burden in any updates that CMS implements with regard to application procedures and evaluation processes for external Healthcare Common Procedure Coding System (HCPCS) Level II code applications. APMA recommended that CMS commit to:

  • confirming receipt of applications within 72 business hours;
  • publishing and adhering to an annual schedule of public meetings;
  • providing applicants at least 30 days’ advance notice of their inclusion on a public meeting agenda; and
  • establishing and regularly maintaining a public database of open applications that is regularly updated with application status in the application cycle.

Request for InformationLandscape Analysis to Leverage Novel Technologies for Chronic Disease Management for Aging Underserved Populations (December 23, 2020)

In its comments to OASH, APMA stressed the role that podiatric physicians and surgeons play in treating chronic disease patients, and how they use novel technologies to optimize chronic disease management and prevent disease progression.

APMA noted that the primary barriers in bringing using novel technologies for patient care are inevitably coding, coverage, and payment concerns. The current mechanism for obtaining coding and coverage for a novel technology is through the CMS Healthcare Common Procedure Coding System (HCPCS) application system, which is difficult to navigate and antiquated.

APMA recommended that a more transparent, streamlined, and modern process can support applicants with proven technologies as they seek to obtain the HCPCS coding that is needed for patients to benefit. APMA also believes that improvements in contractors’ coverage determination processes would further reduce barriers to delivering innovative technologies to Medicare populations.

Additionally, another barrier to increasing patient access to novel technologies is that MACs regularly make errors in programming related to provider types when accounting for new technology-driven solutions or more modern services, discounting podiatric physicians and surgeons frequently from provider types.

Regulatory Relief to Support Economic Recovery; Request for Information (December 21, 2020)

In its comments to HHS, APMA focused on telehealth and remote monitoring physiologic monitoring (RPM). Specifically, APMA urged HHS to permanently allow payment for audio-only telehealth services.

APMA also urged OCR to re-evaluate its enforcement of HIPAA considering new technology and permit common communication tools and applications to be used to provide telehealth services on a permanent basis. APMA asked that coverage of RPM services to new patients be extended on a permanent basis, beyond the public health emergency.

APMA also thanked HHS and CMS for extending the Appropriate Use Criteria for Advanced Diagnostic Imaging Services program’s Educational and Operations Testing Period through calendar year 2021.


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