Council of Medical Specialty Societies (CMSS) Statement on Temporary Payment Parity for Telephone Visits
April 10, 2020
Centers for Medicare and Medicaid Services
U.S. Department of Health and Human Services
Dear Administrator Verma:
We greatly appreciate actions taken by the Centers for Medicare and Medicaid Services (CMS) to enhance payment for telehealth during this public health crisis. The use of telehealth by physician practices has been an important strategy to keep some of our most sick and vulnerable patients away from hospitals and emergency departments. The addition of new telehealth payments by CMS has been a critical change, including the flexibility to provide care via audio-only telephone calls.
During COVID-19, our entire healthcare system is working to keep patients safe at home, avoiding contact with other patients and health professionals to minimize the spread of the virus and flatten the curve. In support of this crucial goal, patients are foregoing face-to-face doctor visits, but many are primarily speaking to their physician via telephone audio only. Many of our most vulnerable patients are least likely to have access to video capabilities, including those who live in more rural areas, the elderly, and those with serious health conditions. Many of the patients who are managing multiple chronic conditions do not have smartphones, or may have a smartphone, but do not have the capabilities to use FaceTime or Skype. These are often the same individuals who most need to practice social distancing from physician practices and clinics—and in some cases, from their own family members—to protect themselves from exposure to the virus while still receiving uninterrupted care.
In order to ensure the healthcare system can provide uninterrupted care for individuals who do not have the capability to utilize videoconference technology, temporary parity in payment and billing codes for audio-only telephone calls visits is urgently needed during COVID-19.
We strongly urge CMS to provide temporary payment parity between audio-only telephone evaluation and management (E/M) codes (99441-99443) and office visit E/M codes (99201-99215). In addition, we ask CMS to immediately provide guidance to Medicare Administrative Contractors (MACs) to ensure that recent CMS guidance and rules are followed appropriately to enable the payment of audio-only telephone E/M claims.
While we understand that CPT codes 99201-99215 are available via two-way, synchronous videoconference telehealth and at comparable rates as if these were in-person visits, we are concerned that many patients are unable to connect via telehealth with their physicians, as they may not have devices compatible to facilitate the use of telehealth. We have heard from our physicians that during this crisis, they have been able to conduct successful audio-only telephone visits with patients, in lieu of in-person or telehealth visits, obtaining about 90 percent of the information they would collect in an in-person or video visit.
The fact that the rates for audio-only phone calls are considerably lower than that for office visit E/M codes creates a financial hardship for practices using these audio-only calls at a time when they are already struggling to stay afloat. Additionally, not reimbursing for telephone visits (99441-99443)—at a payment level on par with in-person visits—disproportionally affects physicians and practices caring for vulnerable patients, including the elderly. This step will support efforts to keep patients safely at home, meet their care needs, and ensure physician practices survive COVID-19 and can continue to provide care after the pandemic.
CMS could provide this temporary parity between office visit codes (99201-99215) and telephone E/M codes (99441-99443) to ensure that patients have maximum ability to engage with their doctors during this public health emergency by correlating RVUs from CPT codes 99201-99203 with CPT Codes 99441-99443 for new patients and from 99212-99214 to 99441-99443 for existing patients. We also urge you to provide guidance/instructions to MACs as soon as possible to enable them to transmit reimbursement for these claims now that they are billable under Medicare. We also urge CMS to include within this guidance, instruction to MACs to remedy telephone E/M claims that were rejected prior to this new guidance being issued by CMS. Again, we emphasize that we request these changes on a temporary basis to enable us to safely provide care while flattening the curve in the context of the COVID-19 pandemic.
Given the broad effect of COVID-19 beyond community-based elderly patients, it is critical that we extend the discussion of telehealth payment policy beyond Medicare. These recommended temporary changes in telehealth payment, including payment parity for telephone visits should extend to both Medicaid and private health insurers (including ERISA plans). Given our broad coalition of specialties, we frequently care for the 20 percent of Americans who are covered by Medicaid, including half of all births in the US, and elderly populations in nursing homes and long-term care facilities. Compliant telemedicine platforms have not penetrated many of these settings and therefore telephone care access is essential. Pediatrics, family medicine, OB/GYN, geriatrics, and other specialties are disproportionally disadvantaged by Medicare-only approaches. Moreover, Medicaid has the additional challenge of requiring adoption of any new intervention/methodology by 56 state Medicaid programs.
Our organizations sincerely appreciate the agency’s swift actions to combat COVID-19. We urge you to consider our recommendations for temporary telehealth reimbursement changes in this letter to build upon existing efforts so that patients can get the critical care they need during these difficult times.
Dr. Helen Burstin, CEO of the Council of Medical Specialty Societies, would be happy to answer any questions at firstname.lastname@example.org.
Council of Medical Specialty Societies
American Academy of Allergy, Asthma & Immunology
American Academy of Dermatology
American Academy of Family Physicians
American Academy of Hospice and Palliative Medicine
American Academy of Neurology
American Academy of Ophthalmology
American Academy of Orthopaedic Surgeons
American Academy of Pediatrics
American Academy of Physical Medicine and Rehabilitation
American Association of Clinical Endocrinologists
American College of Cardiology
American College of Medical Genetics and Genomics
American College of Obstetricians and Gynecologists
American College of Occupational and Environmental Medicine
American College of Physicians
American College of Preventive Medicine
American College of Radiology
American College of Rheumatology
American College of Surgeons
American Epilepsy Society
American Gastroenterological Association
American Geriatrics Society
American Medical Informatics Association
American Psychiatric Association
American Society of Anesthesiologists
American Society for Clinical Pathology
American Society of Colon and Rectal Surgeons
American Society of Hematology
American Society of Nephrology
American Society for Radiation Oncology
American Society for Reproductive Medicine
American Thoracic Society
American Urological Association
Association for Clinical Oncology
Infectious Diseases Society of America
North American Spine Society
Society of Critical Care Medicine
Society of Gynecologic Oncology
Society of Hospital Medicine
Society of Interventional Radiology
Society of Nuclear Medicine and Molecular Imaging
Society of Thoracic Surgeons
Society for Vascular Surgery