Health Panel Comment Letter – PFS Proposed Rule 2020 Revisions – September 2019

The Panel is pleased to offer comments in response to the proposed updates to the CY 2020 Revisions to Payment Policies Under the Physician Fee Schedule (PFS)

The Panel applauds CMS’s attention to rural issues throughout the proposed rule. CMS has
demonstrated its commitment to rural areas in considering innovative telehealth care delivery for
opioid use disorder (OUD), incorporating coding decisions specific to RHCs and FQHCs, and
creating adjustments to payments that reflect the geographic realities of different regions across the

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