To: CMS Administrator Seema Verma
"The CCA believes that providers, particularly those who primarily bill E/M services, should not be penalized during the COVID-19 PHE by being forced to bill the lower valued telephone E/M services when they cannot establish simultaneous audio and visual connections with their patients. Our members continue to deliver the same complex care by telephone as they carefully assess established patients’ ongoing, concurrent health needs. This is equally as true for new patients, particularly those who may have COVID-19, who demand the highest level of expertise and the medical decision making as evidenced by infectious disease specialists who are delivering care remotely."
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