On January 30, ASTRO submitted a comment letter to the Centers for Medicare and Medicaid Services opposing the use of telehealth for the on-treatment visit (OTV) component of the weekly treatment management code (CPT code 77427). Radiation oncologists have been able to meet the direct supervision requirements of the OTV via telehealth since the COVID-19 public health emergency (PHE) via various regulatory actions taken by CMS. This flexibility runs through the end of 2024. Any potential extension of this telehealth flexibility is likely to be addressed in the 2025 Medicare Physician Fee Schedule (MPFS) proposed rule.

It is ASTRO’s position that the radiation oncologist should conduct the face-to-face portion of 77427 in person, recognizing that occasional exceptions and flexibilities may be needed to address rural and underserved communities. The purpose of the letter to CMS was to ask that the code be removed from the list of Medicare telehealth services beginning in 2025, now that the COVID-19 PHE is over.

CMS enters its period of rulemaking for 2025 later this month, and the 2025 MPFS proposed rule is expected to be released in early July. Read the letter for more information.