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CMS Regulation Changes During the COVID-19 PHE

A smiling woman wears her Monarch vest for respiratory therapy at home.

“Put patients over paperwork.”

For healthcare professionals in the throes of the COVID-19 Public Health Emergency (PHE) in early 2020, no sweeter words could have been spoken by the Centers for Medicare & Medicaid Services (CMS). And speak them they did — while announcing sweeping reductions in administrative requirements to help clinicians serve patients more safely and efficiently during the COVID-19 pandemic.1,2

More than a year has passed since then, full of challenges for physicians and patients alike. We asked Kari Roehrich, Executive Director of Managed Care in Hillrom’s Respiratory Health business, to reflect upon how CMS regulation changes during the PHE have impacted patients, prescribers and payers — and what she hopes the industry will take away from the experience.

First, A Review: What Changes Did CMS Enact During the PHE?

Along with other significant changes, the following administrative requirements were temporarily reduced:

  • Medicare will cover respiratory devices and equipment for any medical reason determined by clinicians so patients can get the care they need1
  • Telehealth access has been expanded, and it can now fulfill many face-to-face visit requirements — helping patients reduce their exposure by receiving care at home or in a nursing or assisted living facility1

“In making these changes, CMS was focused on removing as many burdensome requirements as possible so physicians could focus on treating patients,” says Roehrich. “With fewer in-person visits and fewer paperwork requirements, CMS is helping physicians meet the needs of the country – and they did it faster than I think anyone expected. They deserve a lot of credit for that.”

As we look beyond the PHE, what does Roehrich hope the healthcare and reimbursement communities will take away from the experience? Three key points come to mind.

1.    How Can We Continue to Extend the Value of Virtual Care?

For patients with chronic respiratory issues, the benefits of virtual care during the COVID-19 pandemic are clear. Keeping these vulnerable patients out of healthcare environments significantly reduces their exposure — and that, in turn, helps reduce the risk of more hospitalizations in an already over-burdened system. But can we extend virtual care even farther to make other aspects of the healthcare experience more flexible?

“Of course patients have worried about the exposure associated with visiting hospitals or clinics — but we’ve also heard from many patients worried about having someone come into their homes to train them on their therapy devices,” explains Roehrich. “The ability to receive that crucial training virtually means they can still access the therapies they need without leaving their homes — or their comfort zones.”

Beyond respiratory care, Roehrich sees plenty of reasons for the healthcare industry to continue expanding virtual care.

“Virtual care options support patients with mobility issues, patients with busy schedules and patients who don’t live near specialists they need to see,” she explains. “Many patients have told us they would have put off the care they needed during the PHE — or foregone it altogether — had virtual options not been available. We have the technology to make it a larger part of our healthcare system for years to come, and we’re seeing promising signs that payers plan to extend coverage. I hope we see the adoption curve continue to rise.”

2.    How Can We Strike the Right Balance Between Documentation and Patient Care After the PHE?

Although paperwork requirements have been temporarily reduced, CMS still requires documentation of medical necessity before a physician may prescribe a respiratory device. This is proper and necessary to ensure devices go only to patients who need them. But are there other, more burdensome requirements that could be reduced or eliminated to help physicians spend more time with patients beyond the PHE? Roehrich hopes so.

“The physicians we’ve worked with have continued to document medical necessity really well,” says Roehrich. “Moving forward, I hope we can find a good balance between ensuring appropriate utilization and reducing the administrative burden we put on physicians who are trying to get their patients the products they need.”

3.    Could This Experience Help Us Identify Underserved Patients Who Could Benefit From Respiratory Therapy?

Because CMS has temporarily loosened coverage restrictions, Roehrich believes it’s possible we could discover previously untreated patients who could benefit from respiratory therapy devices.

“It will be interesting to see if healthcare teams uncover underserved, or previously untreated, patients with chronic respiratory issues who we can help with these devices — and what types of clinical studies may kick off to help establish the evidence bases to support long-term coverage,” she comments. “If the evidence supports it, it could help us improve care for some of those smaller patient populations that were previously deprioritized from a clinical research perspective.”

Remember: Requirements Still Apply

While administrative requirements have been greatly reduced during the PHE, it’s important to remember these changes are temporary, and there are still requirements in place:

  • Prescriptions are still required
  • Medical necessity must be documented in the patient record

During the PHE and Beyond, We Are Here For You

The PHE is temporary. Our support is here to stay. As regulations evolve, Hillrom will continue to be a good partner to patients, caregivers and CMS to help navigate future developments. And as the healthcare industry continues to seek the right balance between paperwork and patient care, we will be here to help every step of the way.

Learn more about prescribing Hillrom respiratory therapy devices during the PHE here.

Kari Roehrich Author Photo

By Kari Roehrich, Executive Director, Managed Services, Hillrom

Kari has spent more than 20 years working in the medical device industry, focused primarily on reimbursement with government and non-government payers. As Executive Director of Managed Care, she leads Hillrom’s work related to reimbursement in its Respiratory Health division.