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To the United States Congress and Centers for Medicare & Medicaid Services Advisory Committee,

We — the undersigned speech pathologists, occupational therapists, physical therapists, occupational therapy assistants, physical therapy assistants, home health agencies, trainees, staff, researchers, and supporters — recommend an immediate reevaluation of CMS’s policy on restricting telehealth billing for home health therapists given the lack of PPE and the fact that in March, Congress passed the CARES Act, which stated that CMS should do everything in its power to promote the use of telehealth during COVID-19.

As you well know, we are in the midst of a global pandemic, and it is a benefit to public health to keep as many people out of hospitals as possible. Home health providers provide services that keep patients safe at home and lessen the strain on hospital systems. There are over 13,000 Home Health companies in the US that employ essential works in the tens to thousands to reduce the risk and ensure that one of the most vulnerable populations, the elderly/geriatric, avoid readmissions into the hospital. 

Yet home health providers are not a prioritized group to receive PPE, despite the fact we travel house to house every day to see our patients. Hospitals are providing telehealth rehabilitation services when appropriate under CARES, yet home health providers are effectively penalized for doing so because they are “paying for costly telehealth systems and visits without financial support from government payers while, at the same time, being exposed to low-utilization payment adjustments (LUPAs)” -Robert Holly (Home Healthcare News).

We are collectively obligated to promote public health interventions that effectively address the COVID-19 pandemic crisis.

While CMS’s recent work to allow more telehealth visits is a step in the right direction, it falls short of protecting home health providers and our patients.

With hospitals providing the same services as home health providers by telehealth, it is clear that this is an effective solution that should be implemented immediately.

Allowing telehealth visits by home health providers when appropriate will prevent the spread of COVID-19 and mitigate the negative effects of the PPE shortage.

As such, we recommend an immediate change to CMS’s current policy and the creation of a mechanism for telehealth reimbursement for home health providers.

With respect,

Michael Flood Jr. CCC-SLP

Owner/President of Essential Healthcare Staffing

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Ally Cagaanan, Occupational Therapist

Shannon Wooten, Speech-Language Pathologist

Mia Calamba, Physical Therapist Assistant

Joann F., Home Health Supervisor

Tiffany Godley, supporter

Marjorie D., student

Krystal James, In-Home Support

Fatima Nunez, Home Health Coder

Glaiza Joy Senina, RN

Shakila Brown, supporter

Gineekia Welch, supporter

Rhea Prudente, RN

Javaris Weston, supporter

Lakesha Kirkland, supporter

Julie Baronda, RN

Finichia Hoskins, Speech Pathologist

Danielle Campbell, Certified Nurse Assistant

Shavika Mack, supporter

Sabrina Bishop, Public Health Nurse

Arkeedah McCormick, supporter

Dawnielle Davis, supporter

Agniman Eve, RN

Angela Thompson, supporter

La’Conya Manuel, Licensed Marriage and Family Therapist

Erica Franks, Physical Therapist

Cathie Wiggs, Occupational Therapist

Lorraine Goed, Occupational Therapist

Jessica Richard, Occupational Therapist

Alexis Persoff Canfora, Speech-Language Pathologist

Angela Davis, supporter

Patricia Aloisi, Occupational Therapist

Chris Johnson, Mental Health Tech

Maria Nimfa Chambers, Speech-Language Pathologist

Leah Kirkland, supporter