Targeted News Service April 7, 2020
WASHINGTON, April
7 -- Theresa H. Rodgers, president of the American
Speech-Language-Hearing Association, Rockville, Maryland, has issued a
public comment on the Centers for Medicare and Medicaid
Services' proposed rule entitled "Medicare and Medicaid Programs:
Contract Year 2021 and 2022 Policy and Technical Changes to the Medicare
Advantage Program, Medicare Prescription Drug Benefit Program, Medicaid
Program, Medicare Cost Plan Program, and Programs of All-Inclusive Care for the
Elderly". The comment was written on April 3, 2020, and posted
on April 6, 2020:
* * *
On
behalf of the American Speech-Language-Hearing Association (ASHA), I
write to offer comments on the Medicare Advantage (MA) proposed rule for
contract years 2021 and 2022.
ASHA is
the national professional, scientific, and credentialing association for
211,000 members and affiliates who are audiologists; speech-language
pathologists; speech, language, and hearing scientists; audiology and
speech-language pathology support personnel; and students.
ASHA's
comments reflect the ongoing national response to the pandemic of Coronavirus
Disease 2019 (COVID-19), and the President's emergency declaration. ASHA
appreciates that during the national emergency, the Centers for Medicare
& Medicaid Services (CMS) has authorized Medicare Advantage (MA) plans
to expand the categories of clinicians allowed to provide telehealth services
to their beneficiaries, including audiologists and speech-language pathologists
(SLPs).
Section
3703 of the Coronavirus Aid, Relief, and Economic Security (CARES) Act (P.L.
116136) grants the Secretary the authority to waive all requirements within
Section 1834(m) of the Social Security Act in order to expand coverage and
access to all clinically appropriate telehealth services for Medicare
beneficiaries. This broad authority is intended to ensure that beneficiary
needs are effectively met during the national emergency. These changes in
federal law clearly demonstrate that Congress recognizes the value
and effectiveness of enabling qualified health care professionals, such as
audiologists and SLPs, to provide telehealth services to Medicare
beneficiaries.
In
recognition of the value of telehealth, ASHA recommends that CMS reexamine its
existing authority to allow MA plans to expand coverage on a permanent basis.
While federal law would not allow these specialties to provide services via telehealth
to fee-for-service Medicare beneficiaries outside the national emergency
period, ASHA maintains that CMS has the regulatory authority to allow MA plans
to reimburse for services provided by audiologists and SLPs via the Bipartisan
Budget Act (BBA) of 2018 (P.L. 115-123).
In
Section 50323 (2)(A)(i)(I), the law states that "additional telehealth
services" include "benefits [that] are available under Part B,
including services for which payment is not made under section 1834(m) due to
the conditions for payment under such section." Services provided by
audiologists and SLPs are covered Part B services; however, at this time
section 1834(m) does not include these categories of clinicians. As a result,
the authorizing language means that coverage could be extended to additional
categories of health care professionals at the Secretary's discretion. Section
50323 (3)(C) of the BBA grants the Secretary the authority to "specify
requirements for the provision or furnishing of additional telehealth benefits."
Given these provisions, ASHA recommends that CMS exercise its authority to
allow MA plans to include audiologists and SLPs as qualified telehealth
providers on a permanent basis.
Several
factors provide foundational support for allowing MA plans to make these
determinations. For example, numerous state laws recognize audiologists and
SLPs as qualified providers of telehealth services, as do many state Medicaid
programs and other payer policies. Twenty states have included provisions in
licensure laws that authorize audiologists and SLPs to perform services via
telehealth./1
Private
insurers in 30 states have established policies that allow audiologists and
SLPs to provide services via telehealth./2
In
addition, 27 state Medicaid programs authorize audiologists and SLPs to perform
services via telehealth./3
TRICARE
has recently expanded telehealth coverage to therapy services across both
regions as a result of the COVID-19 pandemic.
In
addition, a growing body of research on the use of telehealth for communication
disorders includes studies demonstrating the effectiveness and clinical
equivalence of telehealth and inperson services. For example, research
conducted by the United States Department of Veterans Affairs (VA)
indicated the comparability of audiology services provided via telehealth with
in-person delivery of care./4
Other
published studies also indicate that speech-language pathology services
provided via telehealth are as effective as services provided in-person./5,/6
ASHA
appreciates actions taken by the Administration to broaden access to Medicare
telehealth services so that beneficiaries have greater choices about how,
where, and from whom they receive care. ASHA encourages CMS to revise the rule
as recommended to build on this progress and further enhance beneficiary access
to the hearing, balance, speech, language, swallowing, and cognitive care that
audiologists and SLPs provide.
Thank
you for the opportunity to provide comment on this proposed rule. If you or
your staff have questions, please contact Sarah Warren, MA, ASHA's
director for health care policy, Medicare, at swarren@asha.org.
Sincerely,
Theresa
H. Rodgers, MA, CCC-SLP
2020
ASHA President
April
3, 2020
* * *
Footnotes:
1/ American
Speech-Language-Hearing Association. (n.d.). Licensure Board Telepractice
Requirements: Audiology and Speech-Language Pathology. Retrieved from https://www.asha.org/uploadedFiles/Telepractice-Requirements-and-Reimbursement.pdf.
2/ American
Speech-Language-Hearing Association. (n.d.). Private Insurance Laws and
Regulations: Telepractice Reimbursement, Audiology and Speech-Language
Pathology. Retrieved from https://www.asha.org/uploadedFiles/Telepractice-Requirements-andReimbursement.pdf.
3/ American
Speech-Language-Hearing Association. Medicaid Laws and Regulations:
Telepractice Reimbursement, Audiology and Speech-Language Pathology. Retrieved
from https://www.asha.org/uploadedFiles/Telepractice-Requirements-andReimbursement.pdf.
4/
Gladden, Chad. (2013). The Current Status of VA Audiology. Retrieved
from https://www.ncrar.research.va.gov/Education/Conf_2013/Documents/Gladden.pdf.
5/
Hayman M., Skinner L. and Wales D. (2017). The Efficacy of Telehealth-Delivered
Speech and Language Intervention for Primary School-Age Children: A Systematic
Review. Retrieved from https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5546562/.
6/ Alvares
Robin, Grogan-Johnson Sue, and Rowan Lynne. (2010). A pilot study
comparing the effectiveness of speech language therapy provided by telemedicine
with conventional on-site therapy. Retrieved from https://journals.sagepub.com/doi/abs/10.1258/jtt.2009.090608.
* * *
The
proposed rule can be viewed at: https://www.regulations.gov/document?D=CMS-2020-0010-0002
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