Home Health Proposal Could Improve Access to Telemedicine, Concerns About Home Infusion of Chemotherapy Remain

August 26, 2020

The Association for Clinical Oncology (ASCO) recently submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the Medicare and Medicaid Programs; CY 2021 Home Health Prospective Payment System Rate Update; Home Health Quality Reporting Requirements; and Home Infusion Therapy Services Requirements (CMS-1730-P) proposed rule.

For 2021, CMS is proposing to allow home health agencies (HHAs) to utilize telecommunications technologies in providing care to beneficiaries under the Medicare home health program on a permanent basis, as long as:

  • The telecommunications technology is related to the skilled services provided
  • The telecommunications technology is outlined on the plan of care
  • The telecommunications technology is tied to a specific goal and indicates how such use would facilitate treatment outcomes

ASCO supports CMS’ proposal to make this temporary flexibility a permanent part of the Medicare home health program. The Association asserts that the proposal will help ensure patient access to the latest technology and give HHAs the continued ability to use telecommunications technology as part of patient care. This is especially important to patients with cancer, a vulnerable and often immuno-compromised subset of the Medicare population, who would benefit greatly from the proposal even after the PHE.

However, ASCO has serious concerns about the Home Infusion Therapy Services Requirements proposal, which would establish payment rates for the three categories of home health infusions (including chemotherapy), exclude the home infusion benefit from the home health benefit, and set enrollment standards for qualified home infusion therapy suppliers. Specifically, the Association is concerned about the safety of home infusion for chemotherapy drugs and does not support its use, unless there are extraordinary circumstances and a treating physician—in consultation with the patient—has determined it is the most appropriate alternative.

Read the full comment letter.

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