Comment on CMS-2026-2377-0002

Remo Health is a virtual, interdisciplinary dementia specialty practice operating across four states (Ohio, Washington, California, and Oregon). We are an active CMS GUIDE Model participant delivering longitudinal, team-based dementia care exclusively via telehealth. Our team includes physicians, registered nurses, licensed social workers, care navigators, and clinical pharmacists. We strongly support CMS's proposal to create HCPCS codes GACP1 and GACP2 and add both to the Medicare Telehealth Services List. ACP by Clinical Staff Is Central to Dementia Care — and Currently Uncompensated In dementia care, advance care planning is a longitudinal, iterative process — covering goals-of-care conversations, surrogate decision-maker identification, advance directive completion, and hospice readiness — spanning months or years. This work is primarily performed by our licensed social workers and care navigators. Under current policy, 99497 and 99498 are billable only for the billing practitioner's personal time, leaving substantial clinical staff ACP time entirely uncompensated. GACP1 and GACP2 would correct this for the first time. We strongly support the proposal. Telehealth Is the Only Practical Modality for This Population Dementia patients and their caregivers face significant barriers to in-person care: transportation challenges, caregiver burden, and behavioral symptoms that worsen with disruption. Our experience shows that ACP conversations via telehealth are clinically effective — the ability to include geographically dispersed family members often improves the quality of ACP discussions. Caregiver participation rates are substantially higher via telehealth. For dementia practices, telehealth delivery of ACP is not a convenience — it is the only viable modality. Virtual Direct Supervision Should Explicitly Apply CMS permanently codified virtual direct supervision for incident-to billing at 42 CFR § 410.26 effective January 1, 2026. Remo operates under this framework today. We urge CMS to confirm in the final rule that virtual direct supervision under 42 CFR § 410.26 satisfies the supervision requirement for GACP1 and GACP2. Retain Separate Codes Rather Than a Combined Code We recommend keeping GACP1/GACP2 distinct from 99497/99498. Separate codes allow CMS to track physician versus clinical staff ACP time — data essential to future payment policy. In team-based practices, these time periods are planned and documented separately; a combined code creates billing ambiguity and compliance risk. Separate coding also incentivizes appropriate deployment of non-physician clinical staff for ACP, which is both clinically sound and cost-effective for Medicare. We support permitting GACP1/GACP2 and 99497/99498 to be reported together when time thresholds are met. Conclusion Remo Health enthusiastically supports GACP1 and GACP2, their inclusion on the Telehealth Services List, and virtual direct supervision for their furnishing. These proposals recognize clinical staff labor that has gone uncompensated despite being essential to dementia care. We welcome any follow-up from CMS. Respectfully submitted, Remo Medical Group P.A. / Remo Medical Group CA CMS GUIDE Model Participant | Virtual Dementia Specialty Care