ACC Raises Additional COVID-19 Policy Solutions

Recent comments submitted by the ACC to the Centers for Medicare and Medicaid Services (CMS) thank the Agency for the significant amount of flexibility granted through recent emergency regulations published March 30 and April 30; while also identifying future policy considerations. Among other provisions, the two CMS interim final rules included ACC requests for waivers of telehealth originating site requirements and the addition of telephone management services to the fee schedule. These changes were followed by an increase in payment rates for those services.

However, the ACC notes that patients and clinicians would see additional benefit if given a mechanism to provide cardiac rehabilitation services remotely and were allowed continued flexibility for telehealth services even after the COVID-19 public health emergency in order to address surges that may occur in different parts of the country at different times. Additionally, the simplification or waiving of programs (i.e. the Merit-based Incentive Payment System (MIPS), Medicare Shared Savings Program (MSSP), Bundled Payments for Care Improvement Initiative (BPCI) Advanced, among others) would lessen the administrative burdens of clinicians and practices while responding to COVID-19.

Lastly, the letter identified other future considerations, such as a need for changes to the repayment terms for CMS's now-suspended Accelerated and Advanced Payment Program and the need to address flexibilities in some coverage policies that require minimum procedure volumes given so many non-essential services have been deferred in recent months.

Keywords: ACC Advocacy, Coronavirus, Centers for Medicare and Medicaid Services, U.S., Medicare, Public Health, Medicaid, COVID-19, severe acute respiratory syndrome coronavirus 2, Fee Schedules, Telemedicine

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