NCHR Comments on the Calendar Year 2023 Medicare Physician Fee Schedule

September 8, 2022

The National Center for Health Research (NCHR) appreciates the opportunity to provide public comments on the Proposed Rule: Calendar Year 2023 Medicare Physician Fee Schedule. As a nonprofit think tank that conducts, analyzes, and scrutinizes research on a range of health issues, we have a particular focus on which prevention strategies and treatments are most effective for which patients and consumers. Our aim is to ensure that healthcare consumers are equipped with information that can help them access quality, evidence-based medicine. We are encouraged to see policies in this Proposed Rule that would increase access to quality healthcare for millions of vulnerable Americans.

The public health emergency due to the COVID-19 pandemic has created unique barriers to accessing healthcare services. NCHR supports the proposal for continued expansion of coverage for telemental health services. Throughout the extension period, it is imperative for the Centers for Medicare and Medicaid Services (CMS) to continue to collect data regarding both efficacy and patient satisfaction for telehealth services for mental healthcare, including for audio-only appointments.

There is a large body of research to support the continued use of telehealth for mental health services. Studies comparing in-person mental health appointments with telehealth appointments have shown no difference in desired outcomes, ranging from reductions in anxiety and depression to global functioning.1,2 However, there is little research comparing the efficacy of audio-only appointments to video-based appointments and this preference may differ based on population. Research has shown that older adults are more likely to engage in audio-only rather than video appointments, particularly due to barriers like technical literacy or the cost of the technology.3,4 Data must be collected that provide information regarding the efficacy of audio-only appointments, as well as patient preference and satisfaction between audio-only and video-based appointments. Data collection should continue for the entire extension period, including after the end of the declared public health emergency, should that declaration end prior to the end of the extension period.

We also support the provision to cover substance use disorder (SUD) for Medicare beneficiaries. Studies have shown that older adults with untreated SUDs have a significant increase in medical comorbidity.5 Unfortunately, most older adults are unable to access treatment. Nearly 25% of individuals 65 years and older with perceived need reported cost and limited insurance as their reasoning for not getting treatment, 27% reported lack of information or programs, and 17% reported lack of transportation and inconvenience.6,7 While the majority of admissions for individuals 65 and over are for alcohol use, from 2000 to 2012 a sharp increase in admissions were attributed to both prescription opioids and illicit drugs. This further justifies the urgent need for Medicare to cover treatment options. For those older adults that enter SUD treatment, there are significant improvements. Studies show that even though many traditional treatment programs serve mainly younger people with only 23% of facilities having adult-specific programming in 2019, older adults have better outcomes in comparison to their younger counterparts.5


  1. Carlbring P, Andersson G, Cuijpers P, Riper H, Hedman-Lagerlöf E. Internet-based vs. face-to-face cognitive behavior therapy for psychiatric and somatic disorders: an updated systematic review and meta-analysis. Cognitive Behaviour Therapy. 2018; 47(1):1-8.
  2. Santesteban-Echarri O, Piskulic D, Nyman RK, Addington J. Telehealth interventions for schizophrenia-spectrum disorders and clinical high-risk for psychosis individuals: A scoping review. Journal of Telemedicine and Telecare. 2020 Jan;26(1-2):14-20.
  3. Li H, Glecia A, Kent-Wilkinson A, Leidl D, Kleib M, Risling T. Transition of Mental Health Service Delivery to Telepsychiatry in Response to COVID-19: A Literature Review. Psychiatric Quarterly. 2021 Jun 8:1-7.
  4. Kruse C, Fohn J, Wilson N, Patlan EN, Zipp S, Mileski M. Utilization barriers and medical outcomes commensurate with the use of telehealth among older adults: systematic review. JMIR Medical Informatics. 2020;8(8):e20359.
  5. SAMHSA. (2020). Treating Substance Use Disorder in Older Adults.
  6. Choi, N. G., DiNitto, D. M., & Marti, C. N. (2014). Treatment use, perceived need, and barriers to seeking treatment for substance abuse and mental health problems among older adults compared to younger adults. Drug and Alcohol Dependence, 145, 113–120.
  7. Lin, J. C., Karno, M. P., Grella, C. E., Warda, U., Liao, D. H., Hu, P., & Moore, A. A. (2011). Alcohol, tobacco, and Nonmedical Drug Use Disorders in U.S. adults aged 65 years and older: Data from the 2001–2002 national epidemiologic survey of Alcohol and Related Conditions. The American Journal of Geriatric Psychiatry, 19(3), 292–299.