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WASHINGTON, May 17 -- Marcie Harris-Hayes, professor of physical therapy at the Washington University School of Medicine, St. Louis, Missouri, has issued a public comment on the Centers for Medicare and Medicaid Services' rule entitled "Medicare and Medicaid Programs, Basic Health Program, and Exchanges: Additional Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency and Delay of Certain Reporting Requirements for the Skilled Nursing Facility Quality Reporting Program". The comment was written on May 13, 2020, and posted on May 14, 2020:
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I am writing in response to the request for comments on the Medicare and Medicaid Programs, Basic Health Program, and Exchanges; Additional Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency and Delay of Certain Reporting Requirements for the Skilled Nursing Facility Quality Reporting Program interim final rule with comment period.
I am a professor in physical therapy at Washington University School of Medicine. As a physical therapist, I appreciate the opportunity to provide feedback to CMS on this interim final rule. I respectfully request that you consider my more detailed comments and recommendations provided below.
Expand Provider Types Eligible to Furnish Telehealth under the Medicare Physician Fee Schedule
The coronavirus pandemic demands that health care policymakers, payers, and providers reconsider how care is delivered. I greatly appreciate the actions CMS has taken to add health care providers, including adding physical therapists, to the list of eligible providers who can furnish and bill for telehealth services under Medicare.
However, I urge CMS to take additional steps to ensure patient safety and protect health care providers by using authority granted to it under the Coronavirus Aid, Relief, and Economic Security (CARES) Act, and issue a blanket waiver to expand the types of providers eligible to furnish telehealth services as distant site practitioners under Medicare.
This expansion should include institutional providers that bill for physical therapist services furnished by both physical therapists and physical therapist assistants under the Medicare Physician Fee Schedule -- including home health agencies, rehabilitation agencies, skilled nursing facilities, hospital outpatient departments, and comprehensive outpatient rehabilitation facilities -- during the COVID-19 public health emergency. CMS should simultaneously issue guidance on claims submission via the UB-04 claim form, including necessary modifiers...