The American Association for Respiratory Care (AARC) recently joined forces with the American Association of Cardiovascular and Pulmonary Rehabilitation (AACVPR) in developing comments to the Centers for Medicare & Medicaid Services (CMS) in response to proposed changes to several issues involving pulmonary rehabilitation (PR) services outlined in the agency’s calendar year (CY) 2022 update to the physician fee schedule. Because the issues are important to the pulmonary community, we were joined by nine other societies and patient advocacy groups. Our joint comments, which provide detailed information about the issues and our recommendations, were sent to CMS on September 13, 2021.
Of note is the CMS proposal to expand access to PR services for those individuals who have been diagnosed with COVID-19 and continue to experience persistent symptoms, including respiratory dysfunction, for at least 4 weeks after hospital discharge. Our organizations strongly support expansion to PR access but do not believe eligibility for PR for long-haul COVID-19 beneficiaries should be contingent upon hospitalization. We recommend the decision be based on the physician’s clinical judgment as to whether PR would benefit certain patients and serve to decrease re-hospitalizations, physician visits, and worsening pulmonary status. We also recommend CMS consider additional categories of beneficiaries with non-COPD pulmonary diseases, such as adult respiratory distress syndrome (ARDS), as appropriate to receive this valuable, evidence-based treatment.
In past regulatory actions, CMS offered the flexibility to meet the direct supervision requirement for pulmonary, cardiac, and intensive cardiac rehabilitation services virtually without requiring the physician’s physical presence in the location where services are provided contingent upon the virtual supervision being real-time, two-way audio/visual telecommunications. In the CY 2022 update, CMS extended this policy through the end of the calendar year in which the public health emergency ends, or December 31, 2021. However, CMS is seeking input on whether the policy should be made permanent. We strongly recommend CMS continue to allow virtual direct supervision beyond the public health emergency and extended into 2022 as health care moves increasingly to effective telehealth models. Ultimately, we recommend the policy be made permanent.
Because COVID safety protocols have severely limited access to pulmonary rehabilitation services and continue to do so, the waivers CMS adopted during the pandemic allowed PR beneficiaries throughout the U.S. to benefit from the flexibility to deliver PR sessions via virtual real-time communications technology. Given the current rise in COVID-19 cases due to the delta variant, it is critical that the virtual delivery of pulmonary rehabilitation continue. Studies validate the safety of PR services and offer strong evidence that virtual delivery is an important aspect in improving patient outcomes.
Other issues discussed in our comments include:
- Utilization of two new CPT codes for pulmonary rehabilitation that include monitoring with or without oximetry.
- Conforming changes to terminology, regulatory text, and definitions to improve consistency and accuracy of coverage for pulmonary and cardiac and intensive cardiac rehabilitation.
- Removing the requirement that the physician have “direct patient contact related to the periodic review of the patient’s treatment plan.
- Use of a modifier to identify PR services furnished via telehealth.
We encourage our members to read the comments to familiarize yourself with the details and rationale for the recommendations submitted to CMS which will improve access to pulmonary rehabilitation for those individuals whose health outcomes can benefit from these valuable services.
Email [email protected] with questions or comments, we’d love to hear from you.