Telehealth offers significant advantages to patients of all types, including and especially older Americans with mobility and other age-associated health conditions. We believe telehealth is not a trend but an important tool to facilitate safe, convenient, efficient access for patients. The new minimum surgical procedure thresholds for both new and established TEER programs have no scientific basis, are anti-competitive, and only serve to limit patient access.
If the goals of simplified reporting, increased transparency, broader access, and greater utility cannot be accommodated through the current TVT Registry structure, then CMS should consider an alternative reporting mandate to a patient-centered registry.  

Read more on our comments below.