Alliance for Connected Care Urges HHS to Modernize Payment and Regulation to Support Responsible AI-Enabled Care
FOR IMMEDIATE RELEASE
Alliance for Connected Care Urges HHS to Modernize Payment and Regulation to Support Responsible AI-Enabled Care
Washington, DC — The Alliance for Connected Care today submitted formal comments to the Department of Health and Human Services (HHS) in response to the AI in Clinical Care Request for Information, calling for a modern, modality-agnostic regulatory and payment framework that enables responsible adoption of artificial intelligence in care delivery.
The Alliance recommends that HHS use its authority and work with Congress and states to advance the following objectives:
- Strengthen virtual care foundations for AI-enabled care.
- Recognize AI-enabled care as a natural evolution of connected care, not a new kind of care in need of unique policy or regulatory solutions.
- Clear the decks on longstanding barriers to telehealth and remote patient monitoring that will be equally burdensome to the expansion of AI-enabled care.
- Avoid repeating the policymaking mistakes made in other digital health areas, where narrow allowances later hampered patient access.
- Allow the integration of AI-enabled care into existing medical services, when clinically appropriate
- Pursue regulatory and reimbursement changes that allow for modality-agnostic care delivery to facilitate the expansion of AI-enabled care.
- Circumvent barriers like time-based reimbursement to the expansion of AI-enabled care.
- Further grow AI-enabled care delivery in models based on outcomes, where these changes can be made most easily.
- Enable innovative “regulatory sandboxes” that create AI regulatory relief pathways that allow for temporary exemptions from regulation, subject to rigorous due diligence, safety constraints, and narrowly scoped use cases at the state and federal level.
“AI has the potential to expand clinical capacity, strengthen patient engagement, and improve outcomes — but only if federal policy keeps pace,” said Chris Adamec, Executive Director of the Alliance for Connected Care. “We urge HHS to focus on outcomes, accountability, and program integrity while removing outdated telehealth-era barriers that limit innovation.”
“Patients are already turning to AI tools outside the medical system,” Adamec added. “Federal policy should empower clinicians to responsibly deploy these capabilities within the physician–patient relationship — not allow care to fragment outside of it.”
Read the full letter here or below:
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Open in new tab Alliance for Connected Care Letter on Michigan IMLC Participation
The Alliance for Connected Care sent a letter to Michigan state legislators encouraging them to advance S.B. 60, which would renew participation in the Interstate Medical Licensure Compact (IMLC). This legislation is crucial to Michigan’s continued leadership on health care.
Michigan’s participation in IMLC strengthens access to care in the state. Michigan must continue its participation in IMLC to expand health care access for patients and empower Michigan practitioners as national experts and leaders. The Alliance believes participation in the IMLC should be the minimum for a state promoting greater access through telehealth, as more can be done. After Michigan passes S.B. 60 and renews their involvement in IMLC, the State should consider adopting the Uniform Telehealth Act (UTA) model legislation.
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Alliance for Connected Care Response to Future Directions in Medicare Advantage RFI
The Alliance for Connected Care responded to the Contract Year 2027 Policy and Technical Changes to the Medicare Advantage Program, Medicare Prescription Drug Benefit Program, and Medicare Cost Plan Program proposed rule, which contained a Request for Information (RFI) on the future direction of Medicare Advantage.
The Alliance urged CMS to update network adequacy policies, encourage cross-state licensure, and build on tech-enabled care initiatives, such as the ACCESS Model, in the Medicare Advantage program. We believe these steps will improve patient outcomes and yield downstream savings for the larger Medicare program.
Read the full letter here or below:
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Alliance Leads over 150 Stakeholders in Requesting CMS Extend Provider Location Flexibilities to Virtual-Only Providers
The Alliance for Connected Care and over 150 stakeholders sent a letter to CMS thanking the agency for its leadership in creating location reporting flexibility for practitioners with an in-person practice location.
In addition to this recognition, signers request that CMS begin work on a low-burden means of addressing these concerns for fully remote practitioners. This is an important step in ensuring that providers without a physical practice location can continue to provide critical care for the patients who need it most.
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Alliance Urges Congress to Advance Permanent Telehealth
The Alliance for Connected Care sent a letter to Congressional Leadership, urging a focus on permanent telehealth policy in the upcoming extension package. Permanent or long-term policy is extremely necessary given the previous lapse in access and ongoing uncertainty.
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2025 Year in Review: A Year of Impact, Leadership, and Results
Across 2025, the Alliance for Connected Care continued to be the leading national voice for virtual care, driving concrete policy wins, mobilizing Congress at critical moments, and protecting patient access across Medicare and the commercial markets.
In a year defined by policy uncertainty and high-stakes deadlines, the Alliance for Connected Care didn’t just respond – we led. By shaping legislation, defending patient access, and keeping telehealth front-and-center on Capitol Hill, the Alliance proved once again that when it comes to connected care, no organization delivers more impact.
Read the Alliance’s full recap here or below.
Unlocking Permanent Telehealth Access in the Commercial Market
The Alliance was a driving force in securing a policy victory that delivers long-term certainty for millions of Americans enrolled in high deductible health plans with health savings accounts (HDHP-HSAs). Years of Alliance advocacy to preserve pre-deductible telehealth access paved the way for permanent change, transforming a temporary flexibility into a durable solution. By removing a significant financial barrier to care, the Alliance empowered employers to confidently design benefits that expand affordable telehealth access for working families, particularly those in rural and underserved communities, without unnecessary out-of-pocket costs.
Securing Permanent CMS Policy for Billing from Provider Locations
The Alliance played a decisive role in making permanent a critical CMS policy that allows clinicians to bill for Medicare telehealth services using an enrolled practice location where they are capable of providing in-person care, even when the clinician is physically located elsewhere, such as their home. Without action, this flexibility was set to expire on December 31, 2025. When the policy was not addressed in the CY 2026 Physician Fee Schedule, the Alliance intensified engagement with CMS, holding multiple discussions throughout the year and mobilizing stakeholders to underscore the real-world consequences for patient access. The Alliance will continue to work with CMS on a path that allows the same for virtual-only practitioners, particularly those without a physical practice location to report other than a home address.
Defending and Expanding Remote Patient Monitoring
The Alliance continued its leadership in protecting and strengthening Remote Patient Monitoring (RPM), a cornerstone of modern, patient-centered care. Building on earlier successes securing Medicare coverage and appropriate payment for RPM services, the Alliance remained on the front lines in 2025 to defend RPM from disruptive policy changes that could have reduced access or undermined care delivery. Through sustained engagement, the Alliance engaged with CMS in conversations focused on meaningfully modernizing reimbursement to fully capture inputs of technology-enabled care like RPM.
Leading the Charge on Medicare Telehealth Extensions
When Medicare telehealth access faced expiration in March and September, the Alliance stepped up. Ahead of both the telehealth cliffs, the Alliance mobilized stakeholders, educated policymakers, and provided real-time leadership on Capitol Hill. The result: sustained congressional attention, retroactive payments, and a clear message that telehealth must remain a permanent part of Medicare.
Leading the Fight to Ensure Remote Access to Medication and Controlled Substances
The Alliance led efforts to protect access to medications via telemedicine, pressing the Drug Enforcement Administration (DEA) to establish a permanent framework for the prescribing of appropriate controlled substances via telemedicine, as directed by Congress. In 2025, the Alliance kept the pressure on, creating urgency for clarity about continued access to care and medications. The DEA published a fourth temporary extension, which provides a one-year extension through December 31, 2026.
Relentless Engagement with Federal Policymakers
In 2025, the Alliance delivered an unmatched advocacy footprint, engaging Congress through:
- Dozens of formal comment letters, coalition letters, and statements for hearings;
- Regular briefings and direct outreach to House and Senate offices;
- Rapid-response advocacy prior to government funding deadlines.
Alliance Leads Over 180 Organizations in Urging OMB and DEA to Extend Telehealth Prescribing Flexibilities
The Alliance for Connected Care led over 180 health care providers, innovators, and advocates in urging the Office of Management and Budget (OMB) and Drug Enforcement Administration (DEA) to advance a telemedicine regulation (RIN: 1117-ZA07) continuing access to prescribing through telehealth. Without action, these critical telemedicine authorities will expire on December 31, 2025; patients and providers are facing unacceptable uncertainty and the real risk of care disruptions. These flexibilities have been essential for maintaining continuity of care, particularly for those with mental and behavioral health needs, over the past five years.
Read the full statement here or below:
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Alliance Statement – CMS INNOVATION CENTER ANNOUNCES ADVANCING CHRONIC CARE WITH EFFECTIVE, SCALABLE SOLUTIONS (ACCESS) MODEL
ALLIANCE STATEMENT
CMS INNOVATION CENTER ANNOUNCES TECH-ENABLED ADVANCING CHRONIC CARE WITH EFFECTIVE, SCALABLE SOLUTIONS (ACCESS) MODEL
DECEMBER 2025
The Alliance for Connected Care applauds the Centers for Medicare & Medicaid Services (CMS) on its announcement of the Advancing Chronic Care with Effective, Scalable Solutions (ACCESS) Model. This outcome-aligned payment model represents meaningful progress toward a modernized Medicare program that empowers clinicians to use technology-enabled care for chronic conditions such as hypertension, diabetes, musculoskeletal disorders, and mental health.
For too long, antiquated regulatory and payment barriers have limited the ability of clinicians to deploy digital health tools, including remote monitoring and other tech-enabled care, even when those tools meet patients’ needs and improve outcomes. The ACCESS Model begins to remove these barriers by explicitly supporting flexible, tech-enabled care pathways.
This model aligns directly with what the Alliance advocated in our comments to the Health Technology Ecosystem RFI: healthcare delivery should be seamless across modalities and payment and practice requirements should be modernized to unlock the full potential of digital health. Providers should be able to choose the most clinically appropriate modality without being limited by fee-for-service billing constraints.
As the Medicare population continues to age, and clinician shortages worsen, the use of technology to manage patients with multiple chronic conditions or in high-risk post-acute circumstances are not just an imperative, they are a necessity. The Alliance believes that one key to scaling these services will be enabling technology to extend the capabilities of the clinician. Our current coding and reimbursement structures often stand in the way of this innovation.
The ACCESS model represents the kind of bold, forward-looking policy the Alliance has long advocated for. By compensating quality and outcomes rather than volume, ACCESS ensures patients and providers aren’t forced to weigh outdated regulatory or payment barriers when determining the best modality for care.
The Alliance believes the ACCESS Model is an important first step toward transforming how chronic care is delivered in Medicare and has the potential to become a national standard for technology-enabled, patient-centered care. We look forward to working with CMS to continue to expand access to highly efficient and patient-centric tech-enabled care.
Alliance Submits Statement to House Ways and Means Hearing on “Modernizing Care Coordination to Prevent and Treat Chronic Disease”
The Alliance for Connected Care submitted a statement for the record for the House Ways and Means Health Subcommittee’s hearing on “Modernizing Care Coordination to Prevent and Treat Chronic Disease”.
The Alliance highlighted the important role telehealth plays in improving health care and outcomes for people with chronic conditions. As such, the statement urges Congress to permanently extend Medicare telehealth flexibilities to ensure patients with chronic conditions can receive the high-quality, accessible, and coordinated care they need.
Read the full statement here or below:
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Alliance Leads 450 Stakeholders in Request for Long-Term Fix to Medicare Telehealth
The Alliance for Connected Care co-led a letter, urging federal policymakers to enact a long-term fix for telehealth coverage for Medicare.
Over 450 organizations spanning health care providers, digital health innovators, patient and provider advocacy organizations press Congress to immediately act on a long-term telehealth fix in its next legislative package to ensure stability and provide clarity for patients, providers and the health care system as a whole.
Congress has extended telehealth flexibilities multiple times immediately prior to the looming deadlines. Unfortunately, failure to do so this year has led to an abrupt end to telehealth services for millions of Medicare beneficiaries. This cycle of temporary fixes has resulted in patients and providers facing continued disruptions in care. Another short-term extension is unacceptable.
Read the full letter here or below:
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