Telehealth has played a vital role in health care access and delivery during the COVID-19 pandemic, and it is important that Congress carefully consider which regulatory flexibilities should extend beyond the public health emergency.
The ACS strongly supports amending the Social Security Act such that “originating site” means any site at which the eligible telehealth individual is located at the time the service is furnished via a telecommunications system, including the home of the individual. We believe that such revision will substantially increase access to telehealth services and reduce barriers to care for Medicare beneficiaries.
The ACS also recognizes the benefits of the expanded list of telehealth services and the subregulatory process used to modify the services included on the telehealth services list that were put in place during the COVID-19 pandemic. The ACS recommends that the Centers for Medicare & Medicaid Services be required to conduct a thorough review of all services added to the telehealth services list during the pandemic to determine whether such services remain safe and appropriate to furnish via telehealth after the COVID-19 public health emergency ends.
In addition to revising the “originating site” requirement and maintaining the expanded list of telehealth services, some legislative proposals include permanently expanding the types of practitioners who may furnish telehealth services to include any practitioner that is eligible to bill Medicare. The ACS is concerned that these proposals may create significant scope of practice issues, have unintended consequences for patient safety and appropriateness, and could result in fraud and abuse of telehealth services under the Medicare program.
ACS comments on the Cures 2.0 Act (07/16/2021)