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In a proposed rule, the US Centers for Medicare and Medicaid Services (CMS) gives the green light to expand coverage for telehealth in Medicare Advantage (MA) plans. But when—and if—those changes would affect physical therapists (PTs) remains an open question.

The proposal from CMS would begin covering MA plans in 2020 within a range of areas, including changes for beneficiaries who are dually enrolled in Medicare and Medicaid, and tightened accountability within MA and Medicare Part D programs. But the provisions getting the most attention center on a CMS proposal to allow MA plans to treat telehealth benefits as basic benefits. It's a move prompted by the Bipartisan Budget Act (BBA) of 2018, which set the stage for wider use of telehealth under Medicare.

Under the proposed rule, MA plans would be allowed to offer what are known as "additional telehealth benefits" as basic benefits if they are available under Medicare Part B and deemed "clinically appropriate" for what CMS is calling "electronic exchange" services. Deciding what is and isn't "clinically appropriate" and thereby covered would be left to individual MA plans.

Additionally, the proposed rule would allow MA enrollees to engage in telehealth services in their homes or other locations, rather than requiring them to go to a specific facility. The range of technologies that would qualify is fairly broad under the proposal and includes secure messaging, store-and-forward technologies, telephone, videoconferencing, and other Internet-enabled technologies, as well as "evolving technologies."

"While MA plans have always been able to offer more telehealth services than are currently payable under original Medicare through supplemental benefits, this change in how such additional telehealth benefits are financed (that is, accounted for in payments to plans) makes it more likely that MA plans will offer them and that more enrollees will be able to use the benefits," according to a CMS press release.

APTA has advocated for the increased use of—and reimbursement for—telehealth services by PTs for several years, and is a supporter of the Creating Opportunities Now for Necessary and Effective Care Technologies (CONNECT) Act. The proposal would lift many of the current restrictions on the use of telehealth in Medicare, particularly in MA, accountable care organizations, and certain bundled payment models.

Kara Gainer, APTA director of regulatory affairs, said that while the increased acceptance of telehealth in the proposed rule is a move in the right direction, CMS has yet to respond to the calls of APTA and other stakeholder groups to deliver more clarity on which providers it would expect to be included in any coverage of telehealth services.

"Implementation of the Bipartisan Budget Act provisions will no doubt increase patient access to needed care through electronic exchange, but many more details need to be worked out," Gainer said. "Physical therapists have an opportunity right now to make their voices heard by working with the Medicare Advantage plans they contract with and advocate for coverage of certain physical therapy services, and to explain how that coverage could save money and improve outcomes."

At the CMS level, Gainer also suggests that PTs and other stakeholders comment on the agency's proposals. APTA is reviewing the proposal and will provide comments to CMS by the December 31 deadline.

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