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On behalf of the
ASHA is the national professional, scientific, and credentialing association for 211,000 members and affiliates who are audiologists; speech-language pathologists; speech, language, and hearing scientists; audiology and speech-language pathology support personnel; and students.
ASHA's comments reflect the ongoing national response to the pandemic of Coronavirus Disease 2019 (COVID-19), and the President's emergency declaration. ASHA appreciates that during the national emergency, the
Section 3703 of the Coronavirus Aid, Relief, and Economic Security (CARES) Act (P.L. 116136) grants the Secretary the authority to waive all requirements within Section 1834(m) of the Social Security Act in order to expand coverage and access to all clinically appropriate telehealth services for Medicare beneficiaries. This broad authority is intended to ensure that beneficiary needs are effectively met during the national emergency. These changes in federal law clearly demonstrate that
In recognition of the value of telehealth, ASHA recommends that CMS reexamine its existing authority to allow MA plans to expand coverage on a permanent basis. While federal law would not allow these specialties to provide services via telehealth to fee-for-service Medicare beneficiaries outside the national emergency period, ASHA maintains that CMS has the regulatory authority to allow MA plans to reimburse for services provided by audiologists and SLPs via the Bipartisan Budget Act (BBA) of 2018 (P.L. 115-123).
In Section 50323 (2)(A)(i)(I), the law states that "additional telehealth services" include "benefits [that] are available under Part B, including services for which payment is not made under section 1834(m) due to the conditions for payment under such section." Services provided by audiologists and SLPs are covered Part B services; however, at this time section 1834(m) does not include these categories of clinicians. As a result, the authorizing language means that coverage could be extended to additional categories of health care professionals at the Secretary's discretion. Section 50323 (3)(C) of the BBA grants the Secretary the authority to "specify requirements for the provision or furnishing of additional telehealth benefits." Given these provisions, ASHA recommends that CMS exercise its authority to allow MA plans to include audiologists and SLPs as qualified telehealth providers on a permanent basis.
Several factors provide foundational support for allowing MA plans to make these determinations. For example, numerous state laws recognize audiologists and SLPs as qualified providers of telehealth services, as do many state Medicaid programs and other payer policies. Twenty states have included provisions in licensure laws that authorize audiologists and SLPs to perform services via telehealth./1
Private insurers in 30 states have established policies that allow audiologists and SLPs to provide services via telehealth./2
In addition, 27 state Medicaid programs authorize audiologists and SLPs to perform services via telehealth./3
TRICARE has recently expanded telehealth coverage to therapy services across both regions as a result of the COVID-19 pandemic.
In addition, a growing body of research on the use of telehealth for communication disorders includes studies demonstrating the effectiveness and clinical equivalence of telehealth and inperson services. For example, research conducted by the
Other published studies also indicate that speech-language pathology services provided via telehealth are as effective as services provided in-person./5,/6
ASHA appreciates actions taken by the Administration to broaden access to Medicare telehealth services so that beneficiaries have greater choices about how, where, and from whom they receive care. ASHA encourages CMS to revise the rule as recommended to build on this progress and further enhance beneficiary access to the hearing, balance, speech, language, swallowing, and cognitive care that audiologists and SLPs provide.
Thank you for the opportunity to provide comment on this proposed rule. If you or your staff have questions, please contact Sarah
Theresa H. Rodgers, MA, CCC-SLP
2020 ASHA President
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5/ Hayman M., Skinner L. and Wales D. (2017). The Efficacy of Telehealth-Delivered Speech and Language Intervention for Primary School-
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The proposed rule can be viewed at: https://www.regulations.gov/document?D=CMS-2020-0010-0002
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