April 9, 2020

The Honorable Seema Verma
Administrator
Centers for Medicare & Medicaid Services
200 Independence Avenue, SW
Washington, DC 20201

Dear Administrator Verma:

The Pulmonary Fibrosis Foundation (PFF) is grateful for the changes that the Centers for Medicare and Medicaid Services (CMS) has made to protect the community during the COVID-19 pandemic. The PFF especially appreciates the swift implementation of modifications to requirements for oxygen certification and delivery that CMS recently implemented because many pulmonary fibrosis (PF) patients rely on supplemental oxygen.

Pulmonary fibrosis patients are at high-risk of complications related to COVID-19 and need protections that reduce their chance for exposure to the virus. At the same time, many pulmonary fibrosis patients rely on pulmonary rehabilitation (PR) services. PR has been shown to improve many PF patients’ exercise capacity and health-related quality of life. Because there are limited treatment options for PF, pulmonary rehabilitation is all the more essential for helping to maintain PF patients’ health.

PR programs are medically directed, supervised, and are usually provided in an outpatient setting. Most of these PR programs have been suspended because of the social distancing guidelines that are currently in place. There is currently no mechanism for reimbursement for PR services that are conducted remotely in the patient’s home. CMS has recently allowed for outpatient evaluation and management (E&M) services to be reimbursed for remote home visits, but this does not include PR services. A similar approach is needed for PR services for a number of reasons:

1.  Patients with pulmonary fibrosis may derive many benefits from PR, including improved dyspnea and quality of life, more efficient use of oxygen, and weight loss.

2. Regular contact with PR professionals would help to address many of the behavioral health and psychosocial aspects of PF patients’ care during the COVID-19 pandemic, such as nutritional choices, access to food, smoking and alcohol consumption, mental health concerns, stress management techniques, and medication adherence. These services are important to the long-term health of patients—particularly during this time of unprecedented disruption, uncertainty, and stress.

3. Patients who are not engaged in PR during the COVID-19 pandemic are highly likely to drop out of PR altogether and not return to the programs once it is safe to do so.

4. The inability to provide for reimbursable PR services during the COVID-19 pandemic will likely result in layoff of PR professionals and jeopardize the viability of some, if not many, PR programs. The depletion of the workforce will exacerbate an already significant problem of limited access to PR programs in many parts of the United States.

The PFF urges CMS to allow for the temporary provision and reimbursement of home-based PR services for the duration of the COVID-19 pandemic. If you have questions, please contact Kate Gates, PFF Senior Director of Programs, at 312.224.9820 or kgates@pulmonaryfibrosis.org.

Sincerely,

William T. Schmidt
President & CEO