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CMS Issues Guidance Amid COVID-19 Response


As the Centers for Medicare and Medicaid Services (CMS) and Congress continue their work to combat the coronavirus (COVID-19) public health emergency, NAACOS has developed a webpage linking to key government and NAACOS resources to assist ACOs. NAACOS is also busy working with ACO champions on Capitol Hill and the administration to advocate for CMS to provide additional relief and resources to ACOs, including by granting greater flexibility with upcoming quality reporting and application deadlines for ACOs.


These are trying times for ACOs and the healthcare industry as a whole, and NAACOS is committed to supporting and assisting you in your work during this critical time. We encourage ACOs to share your feedback on how COVID-19 is affecting your organization and how we can best support you during this time by emailing

In an effort to reduce the spread of COVID-19, CMS today issued guidance on the expanded use of telehealth to address the COVID-19 public health emergency. Congress, in a bill signed into law on March 6, waived Medicare’s usually restrictive geographic and site-of-care limitations on telehealth coverage and reimbursement in instances of public health emergencies. This will temporarily grant all Medicare providers, including those not in ACOs, access to telehealth, including in patients’ homes. Wider use of telehealth has been an issue NAACOS has long advocated for, and we are happy to see this change and additional guidance from CMS.

Specifically, CMS issued a list of frequently asked questions, outlining what services are covered, what providers are eligible for the expanded telehealth opportunities and how to bill for these services. Importantly, CMS says it won’t enforce a requirement under the March 6 law that states patients must have seen a provider (as identified by their TIN) within the last three years. CMS also states telehealth can be preformed on all patients, not just those with COVID-19. In a separate notice, the HHS Inspector General said it will allow healthcare providers to reduce or waive beneficiary cost-sharing for telehealth visits paid for by Federal health care programs.

CMS updated its fact sheet on various ways to use technology to treat patients, including through the use of “virtual check-ins,” which are short patient-initiated communications with a healthcare practitioner, and “e-visits,” which are non-face-to-face patient-initiated communications through an online patient portal.

If you have additional questions, please reach out by emailing

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