The AAMC submitted comments to the Centers for Medicare & Medicaid Services (CMS) on July 7 in response to the agency’s second interim final rule [see Washington Highlights, May 1] with comment period to issue policy and regulatory provisions in response to the COVID-19 Public Health Emergency (PHE).
The AAMC continues to support and recognize the significant actions taken to support hospitals and physicians by providing regulatory relief and flexibility throughout the health care system. In its comments, the AAMC supports:
- Telehealth waivers and flexibilities included in the interim final rules published April 6 and May 8.
- Exclusion of increased inpatient beds from the calculations to determine indirect medical education (IME) payments.
- Expansion of services under the primary care exception to the teaching physician regulations.
- Inclusion of time spent by residents at another hospital for the purposes of direct graduate medical education and IME payments.
- Temporary expansion locations of a hospital to include the patient’s home, but requested the CMS eliminate the requirement to submit addresses of temporary locations to the CMS Regional Office due to significant burden.
- Inclusion of Food and Drug Administration-authorized COVID-19 serology tests for Medicare coverage.
- Delayed implementation of Merit-based Incentive Payment System qualified clinical data registry measurement.
- Consistent approach to Extraordinary Circumstance Exception policies across hospital quality reporting and performance programs and urged the CMS to suspend the hospital quality performance programs during the PHE.
- Adjustments to the Medicare Shared Savings Program calculations to address the unanticipated increase in expenditures due to the PHE and urged the CMS to address the impact of 2020 calendar year expenditures on 2021 risk adjustment in the program.
The AAMC also urged the CMS to take action to make some policies permanent and to work with Congress where necessary, such as with telehealth, to ensure patients can continue to benefit from these health care delivery changes after the PHE ends.