3/ Reinforce this language: *Permanently strike Social Security Act section 1834(m) (originating site, geographic restrictions, limitation on provider type, telecommunications modality).*
4/ Add this language: Make payment parity with in-person services for telehealth services provided by telephones if they incorporate two-way audio-visual functionality (i.e., smartphones) permanent beyond the PHE.
5/ Add this language: Make payment parity with in-person services for audio-only telephonic telemedicine permanent beyond the PHE. This is critical for Medicaid populations especially and is a major equity issue.
6/ Add this language: Permanently expand the types of healthcare professionals that can furnish distant site telehealth services beyond the PHE. Expanded list of healthcare providers now includes physical therapists, occupational therapists, and speech language pathologists.
7/ Add this language: Remove barriers to providing telehealth services across state lines for licensed providers including social workers, speech therapists, occupational therapists, behavioral health therapists, as well as physicians.
8/ Add this language: Make Office of Civil Rights (OCR) exercise enforcement discretion regarding HIPAA requirements permanent. This provision is likely the most impactful provision to impact the commercial insurance space
9/ Add this language: Remove Cost Sharing for telehealth, Remote Patient Monitoring (RPM), non-face-to-face care management, virtual care, and related digital health services.
10/ Add this language: Remove Civil Monetary Penalties (CMP) for providing patients with digital medical devices. This will dramatically improve equitable distribution of innovation to the poor.
11/ Add this language: Require Center for Medicaid and CHIP Services to issues guidance to states to adhere to the above mentioned provisions. Perhaps most important/time sensitive modification to @brianschatz language. We can't keep innovating Medicare & leave Medicaid behind
12/ As I pointed out in this @businessinsider https://twitter.com/businessinsider/status/1272538837827358723: to fill in the blindspot of #Telemedicine, #digitaltherapeutics key to access and quality of care. Prescription Digital Therapeutics Act from @SenCapito @SenatorShaheen https://www.congress.gov/bill/116th-congress/senate-bill/3532/text can help...
13/ Add this language: Update the language of the Medicaid Drug Rebate Program (SSA Sect 1927) to include a specific category for digital therapeutics. States rely on about $25B in drug rebates per year. Digital therapeutics companies would be willing to pay.
14/ Time's running out. If law doesn't get passed b/f end of July, patients will start yelling at their doctors for making them leave comfort/safety of their home for visit, doctors will yell at plans, plans will yell at CMS. Yelling will turn into voting. https://twitter.com/AndreyOstrovsky/status/1272957222235123714
You can follow @AndreyOstrovsky.
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