APWCA collaborated with the Alliance of Wound Care Stakeholders to submit comments to the Centers for Medicare and Medicaid Services (CMS) that supported the following COVID-19 provisions:

• Reimbursement for telehealth at the non-facility rate, as appropriate, when submitted with a 95 modifier and the place of service corresponding to where that service would have been provided had the service been rendered in person
• Expansion of telehealth services generally
• Choice of medical decision making or total time when determining the level of office/outpatient E/M furnished via telehealth
• Ability to provide virtual check-ins, telephone E/Ms, and e-visits to both new and established patients;
• Ability to provide direct supervision via real time interactive audio and video technology; and
• Coverage and payment for telephone evaluation and management services