60 Day Public Comment Response

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60 Day Comments for Additional Telehealth Benefits (ATB)

CMS Response

United
Health Care
(UHC)

United has expressed concern about the difficulties in
trying to discretely tie filed ATB to the specialty provider
offering that benefit. They give an example of trying to
crosswalk the ATB filed benefit category of urgent care to
the provider specialty types CMS listed as options in the
reporting Element C.
The concern is that urgent care is a covered benefit that
Medicare Advantage (MA) plans can file as an ATB benefit,
but is a healthcare service that can be provided by a
variety of different provider specialty types. Generally, the
MA organization anticipates that most urgent care
services for this ATB benefit category will be provided by
primary care provider specialty types. However, there may
be exceptions based on the specific member’s condition
or the specific physicians available for an urgent care
telehealth visit request at a specific point in time.
Therefore, in this example, United would plan to select
primary care in our reporting submission since most
urgent care telehealth visits would be provided by primary
care specialty physicians. There would not be an attempt
to identify all other provider specialty types that might
deliver urgent care telehealth visits based on the member
conditions and the specific provider specialty availabilities
at the time of the visit. United has attempted to
crosswalk a portion of the Medicare Specialty codes
referenced in the link at the bottom of the proposed ATB
Part C Reporting Requirements to the HSD Table Specialty
codes. They have attached is a document that crosswalks
HSD Specialty codes (column E) to the Medicare Specialty

Thank you for your comments and recommendations. We
understand the concern that the reporting of certain specialties
may be duplicative and burdensome to plans, therefore were
are removing the ATB reporting section from the Part C
Reporting Requirements in 2021.

codes (column A) and request that CMS confirm the
accuracy of this crosswalk.
United
Health Care
(UHC)

UHC also recommends that CMS consider the attached
crosswalk or develop a similar document to tie the
Medicare codes to the corresponding HSD specialty codes
to ensure consistency within the industry. This will help
both CMS and MA organizations with data integrity and
transparency regarding specialties considered qualified
specialties for the ATB.

Thank you for your comments and recommendation. However,
we are removing the ATB reporting section from the Part C
Reporting Requirements in 2021.

QUEST

Is a physical location required for a provider, and can they
supplement with telehealth to allow members a choice in
how they receive care?

As Additional Telehealth Benefits are defined in 42 CFR §
422.135, an MA plan may treat additional telehealth benefits as
basic benefits covered under the original Medicare fee-forservice program for purposes of this part 422 provided that the
requirements of this section are met. If the MA plan fails to
comply with the requirements of this section, then the MA plan
may not treat the benefits provided through electronic exchange
as additional telehealth benefits, but may treat them as
supplemental benefits as described in § 422.102, subject to CMS
approval.

QUEST

Can telehealth be the only option for certain types of care
at which point there is no physical location for the
provider?

QUEST

Do providers have the appropriate state licensure to serve
the entire service area?

QUEST

Should the quality of the telehealth provider and the care
they are providing be a measured consideration?

An MA plan furnishing additional telehealth benefits must:
furnish in-person access to the specified Part B service(s) at the
election of the enrollee.
Please refer to the definition of additional telehealth benefits in
42 CFR § 422.135, as this section only requires organizations to
report on Additional Telehealth Benefits
An MA plan furnishing additional telehealth benefits may only
do so using contracted providers. Coverage of benefits furnished
by a non-contracted provider through electronic exchange may
only be covered as a supplemental benefit.
Thank you for your comment, but quality of care is not collected
in this reporting section.

QUEST

QUEST

QUEST

QUEST

Quests wants CMS to consider incorporating additional
identifying telehealth fields in the HSD tables to
accommodate for the identification of telehealth
providers in network adequacy report filings. For instance,
information about whether a provider sees patients via
telehealth, only via telehealth or both may be helpful.
More importantly, knowing the breadth of providers
offering telehealth services in a particular specialty in a
service area could be useful in determining the availability
of virtual care and offer a broader perspective for future
policy decisions
The new telehealth network adequacy changes allow
plans to receive credit at the contract level. As the
guidance is written today, plans are attesting they have
telehealth coverage for all members in the entire contract
service area. Should plans be required to indicate if their
telehealth coverage is fulfilled by a multi-state provider or
via an independent provider as a complement to in-person
care?
Quest recommends from a consumer standpoint to collect
both provider and facility telehealth attributes. Including
this information in directories would inform consumers of
the virtual formats available for care (i.e. audio, audiovisual) and what types of providers and services are
offered through telehealth. Consumers may base plan
selection decisions on how quickly they can receive
telehealth day or night, or if their primary care physician
will also see them via telehealth.
To determine if ATB is a cost saver or a cost inflator, Quest
recommends leveraging claims data to measure the
number of telehealth appointments that lead to follow up

Thank you for your recommendation, however the reporting of
additional telehealth benefits in this section is not related to
network adequacy. Validation for telehealth providers selected
on HSD tables during triennial network reviews is conducted
during the exceptions process.

The collection of ATB in this reporting section was not related to
the telehealth credit provided for Network Adequacy. For
Network Adequacy HSD/HPMS telehealth related questions,
please contact the DMAO portal at https://dmao.lmi.org/

Thank you for your recommendation, We are eliminating the
collection of ATB from the Part C Reporting requirements for
2021

Thank you for your comment, but we believe that this outside of
the scope of collection for the ATB reporting section.

in person visits, or vice versa in person visits that could
have been served via telehealth.
Carol
BellaviaExcellus

Anonymous

The commenter is seeking clarification of the drop down
list mentioned in the crosswalk document. The technical
specifications do not indicate use of a drop down list for
this data element. They indicate to utilize the two-digit
specialty code. Is there going to be some sort of drop
down list or is it simply reference to using the two digit
specialty code?
For Data Element B, "If yes, list the number of Medicare
Part B provider specialty types for which Additional
Telehealth benefits are offered." Would CMS please
confirm that CMS is
requesting the total number of specialty types being
offered? If so, we believe that the word "list" should be
changed to "enter"

The MA plan will enter the specialty code for an ATB service not
included among the selections provided in the reporting
template. However, we are removing this reporting section for
the 2021 year.

Thank you for your recommendation. The proposed edit to Data
Element B does clarify the method we expected plans to report
specialty types. However, we are eliminating the collection of
ATB from the Part C Reporting Requirements for 2021