PEPC Submits Comments in Response to PTAC’s Review of Telehealth and Physician-Focused Payment Models

On October 30, the Partnership to Empower Physician-Led Care (PEPC) submitted comments to the Physician-focused Payment Model Technical Advisory Committee (PTAC) in response to a request for public input to inform PTAC’s review of telehealth and Physician-Focused Payment Models (PFPMs).  

General Comments: 

  • PEPC believes that telehealth services should enhance and deepen, rather than disrupt, the physician-patient relationship. Efforts to expand telehealth should focus on value-based care as an initial use case and emphasize the delivery of telehealth services by existing providers with a longitudinal relationship with the patient, especially the primary care provider.
  • We do not need new structures, or a “virtual medical home” that is different from existing care coordination models. The payment model is already the catalyst for coordinated and integrated care delivery.
  • Continued research is needed to better understand services appropriate for telehealth versus in-person care. APMs are an ideal opportunity for continued experimentation with a wider range of virtual services.
  • We do not believe that additional program integrity requirements within APMs are needed. The program integrity checks that exist in the current Medicare program are sufficient to determine fraud and abuse.
  • Physicians and practices leading value-based models incorporating telehealth will be able to naturally provide telehealth education, as we expand adoption of these models and align incentives for patient engagement through both office visits and virtual interactions. 
  • Privacy restriction requirements on the use of certain communications technologies should vary based on the level of risk and allow greater flexibility in technology for smaller practices without sophisticated telehealth platforms, or when these tools are requested by the patient.

Read the full comment letter here.

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