Dear Secretary Becerra and Administrator Brooks-LaSure,
On behalf of the Cystic Fibrosis Foundation, we write in response to the 2024 Medicare Physician Fee Schedule. Telehealth has improved access to care for many people with CF, particularly those with lower incomes or people living in rural areas, and this proposed rule is an important step for preserving access to these services.
Cystic fibrosis is a life-threatening genetic disease that causes the body to produce thick, sticky mucus that clogs the lungs and digestive system, which can lead to life-threatening infections. Cystic fibrosis is both serious and progressive; lung damage caused by infection is irreversible and can have a lasting impact on length and quality of life. Recently approved genetically-targeted drugs that address the underlying cause of CF are available for patients with specific genetic profiles and have contributed to significant increases in life expectancy. With these advances, more people with CF are aging onto Medicare than ever before.
We provide the following response to the Centers of Medicare and Medicaid Services (CMS) proposed 2024 Medicare Physician Fee Schedule.
Geographic Restrictions and Originating Site
Before the COVID-19 public health emergency, Medicare rules largely limited use of a patient’s home as the originating site to those living in rural areas or with a specific condition. This proposed rule extends current telehealth flexibilities for geographic requirements and expands the originating sites to include the patient’s home and other sites deemed clinically appropriate by CMS. The CF Foundation supports the proposed rule to improve equitable health care access.
We support policies to extend the process of adding clinically appropriate telehealth services included on the Medicare Telehealth Services List through December 31, 2024. As more data becomes available, it is important the Department can act efficiently and effectively to ensure patients can access the care they need.
While audio-only visits are not suitable for all health care services and not a substitute for in-person care, there are a number of aspects of a regular CF visit that can be conducted through the phone. For instance, clinicians can easily review medical history, current medications, and symptoms, and adjust a patient’s care plan. CF patients and care teams can also review data from home spirometers to track trends in lung function. For CF providers, listening to a patient’s cough can also provide actionable information about potential exacerbations. We support provisions in this proposed rule to continue providing audio-only services for the near future and ask Department to work with Congress to develop and implement a long-term solution.
Audio-only services can also promote health equity by facilitating access to telehealth services for low-income and rural communities who are more likely to have limited or no access to the internet or insufficient broadband to support video conferencing. Millions of Americans still lack access to high-speed internet and in 2022, more than 4 in 10 Californians with low incomes (42%) received a phone telehealth visit. At the beginning of the public health emergency, CMS established a temporary coverage policy for audio-only telephone visits, ensuring patients without access to the internet or video platform are still able to receive needed care while avoiding potential exposure to coronavirus. The Department should bear in mind these health equity considerations as it develops long-term telehealth policies.
Expansion of Behavioral Health Services
Ensuring access to mental health services is critical for people with CF to maintain their overall health and quality of life. In 2015, the CF Foundation published guidelines on screening and treatment for depression and anxiety among individuals with CF and caregivers for children with CF. Over the course of the pandemic, there have been increased rates of anxiety and depression among people with CF similar to overall national trends. Given the increased need for services and concerns about the availability of mental health providers, we strongly support the proposed rule that increase the type of providers and the valuation of services covered by Medicare in order for patients to access to these vital services.
Services Addressing Health-Related Social Needs
Given the increasing recognition about the importance of whole person care and awareness of social determinants of health, we support CMS’s commitment to develop a payment and coding model that would increase screening for social risk factors in this proposed rule. We agree with CMS that these services contribute to equity, inclusion, and access to care for the Medicare population and improve the outcomes for patients in underserved and low-income populations. We believe incorporating this coding on a permanent basis will increase referrals for critical support services.
The pandemic has demonstrated the importance of telehealth services and provided evidence that certain barriers to access are no longer necessary. The CF Foundation appreciates your continued commitment to improving access to telehealth and thanks you for your leadership on this important issue for people with cystic fibrosis.