CMS Physician Fee Schedule Proposed Rule


 The National Health Council (NHC) appreciates the opportunity to provide comments on the above-referenced Proposed Rule [the Physician Fee Schedule (PFS)], particularly on issues of access to telehealth services for mental health and diagnostic services. 

Created by and for patient organizations over 100 years ago, the NHC brings diverse organizations together to forge consensus and drive patient-centered health policy. We promote increased access to affordable, high-value, sustainable health care. Made up of more than 140 national health-related organizations and businesses, the NHC’s core membership includes the nation’s leading patient organizations. Other members include health-related associations and nonprofit organizations including the provider, research, and family caregiver communities; and businesses representing biopharmaceutical, device, diagnostic, generic drug, and payer organizations. 

We greatly appreciate the efforts of CMS to consider telehealth flexibilities and payment methodologies, such as allowing a patient’s home to be an originating site of care and the allowance of audio-only visits, that have allowed more patients to access telehealth services during the pandemic. We also welcome the opportunity to continue working with you as you consider further extending telehealth flexibilities in this and other payment programs. 

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