In a July 1 letter to the Centers for Medicare & Medicaid Services (CMS), AAPM&R submitted comments regarding the additional policy and regulatory revisions in response to the COVID-19 public health emergency (PHE).
In our letter, we advocated for:
- Scope of Practice—we asked CMS to reinstate physician supervision requirements after the PHE. AAPM&R asserts that physiatrists and qualified rehabilitation physicians should be maintained as the leaders of patient care in IRFs to ensure appropriate recovery of these complex patients.
- Care Planning for Medicare Home Health Services—with the volume of patients needing adequate home health services following discharge after being treated for COVID-19, there is a more significant need in this space during the PHE which justifies using non-physician providers (NPPs) in this role. However, as we return to the provision of pre-PHE patient care, AAPM&R strongly disagrees with the proposal that these regulations become permanent. We recommend that physician certification of home health services remain the care standard. AAPM&R asserts that care planning for home health services requires specialty training which NPPs do not have.
- Payment for Audio-Only Telephone Evaluation and Management Services—as we noted in our comments to the first PHE interim final rule, the ways in which physicians are being asked to provide telephone services during the COVID-19 pandemic do not coincide with the original intention of the telephone codes, nor do they coincide with the way those codes were valued by the RUC. Increasing payment for these services helps to ensure that patients continue to receive high-quality care despite barriers that may prevent use of audio-visual technology.
We will notify you of any updates as we receive them. Read our previous letters to CMS regarding COVID-19 aid.