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.
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:
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:
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.
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.