NCHR’s Comments to CMS on the 2022 Medicare Physician Fee Schedule

September 13, 2021

The National Center for Health Research (NCHR) appreciates the opportunity to provide public comments on the Proposed Rule: Calendar Year 2022 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. In our comments, we will focus on telehealth issues for mental health services.

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 telehealth mental health services until December 31, 2023. Throughout the extension period, it is imperative for the Centers for Medicare and Medicaid Services (CMS) to continue to collect data regarding efficacy as well as 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 improvements in global functioning.1,2 However, there is little research comparing the efficacy of audio-only appointments to video-based appointments and access to and preference for these options may differ based on demographic factors and diagnosis. For example, research has shown that older adults are more likely to engage in audio-only rather than video appointments,3 particularly due to barriers like technical literacy or the cost of the technology.4 Data are needed to 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, even after the end of the declared public health emergency, should that declaration end prior to the end of the extension period.

The Proposed Rule indicates that patients will have the ability to opt-out of video-based appointments. NCHR believes this flexibility is warranted to meet the unique needs of different patient populations. However, the Proposed Rule should be clarified to describe the process for patients to indicate appointment preference, and these preferences should be monitored by their provider to ensure that high-quality healthcare is administered.


  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.