Alliance Letter Regarding Telehealth Fraud
The Alliance for Connected Care sent a letter to HHS Office of Inspector General (OIG) Principal Deputy Inspector General Grimm urging OIG to update posts on “telehealth fraud” to better distinguish traditional fraud from telehealth fraud. The Alliance supports several recommendations to address improper telehealth payments:
- Conduct periodic post-payment reviews to disallow payments for errors for which telehealth
claim edits cannot be implemented (for example, unallowable originating sites or unallowable
means of communication - Work with MACs to implement all telehealth claim edits listed in the Medicare Claims Processing
Manual; - Offer education and training sessions to practitioners on Medicare telehealth requirements and
related resources.
In addition, the Alliance requested OIG consider meeting with experts to learn about the tools and tactics that can best differentiate legitimate telehealth providers from fraud actors pretending to offer telehealth.
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Open in new tab A current and future outlook on upcoming technologies in remote monitoring of patients with heart failure
A current and future outlook on upcoming technologies in remote monitoring of patients with heart failure
Heart failure is a major health and economic challenge in both developing and developed countries. Despite advances in pharmacological and device therapies for patients with a reduced left ventricular ejection fraction (LVEF) and heart failure, their quality of life and exercise capacity are often persistently impaired, morbidity and mortality remain high and the health economic and societal costs are considerable. For patients with heart failure and preserved LVEF, diuretic management has an essential role for controlling congestion and symptoms, even if no intervention has convincingly shown to reduce morbidity or mortality. Remote monitoring might improve care delivery and clinical outcomes for patients regardless of LVEF. A great variety of innovative remote monitoring technologies and algorithms are being introduced, including patient self-managed testing, wearable devices, technologies either integrated into established clinically indicated therapeutic devices, such as pacemakers and defibrillators, or as stand-alone are in development providing the promise of further improvements in service delivery and clinical outcomes. In this article, we will discuss unmet needs in the management of patients with heart failure, how remote monitoring might contribute to future solutions, and provide an overview of current and novel remote monitoring technologies.
Sensor, Wearable, and Remote Patient Monitoring Competencies for Clinical Care and Training: Scoping Review
Sensor, Wearable, and Remote Patient Monitoring Competencies for Clinical Care and Training: Scoping Review
Abstract
Sensor, wearable, and remote patient monitoring technologies are typically used in conjunction with video and/or in-person care for a variety of interventions and care outcomes. This scoping review identifies clinical skills (i.e., competencies) needed to ensure quality care and approaches for organizations to implement and evaluate these technologies. The literature search focused on four concept areas: (1) competencies; (2) sensors, wearables, and remote patient monitoring; (3) mobile, asynchronous, and synchronous technologies; and (4) behavioral health. From 2846 potential references, two authors assessed abstracts for 2828 and, full text for 521, with 111 papers directly relevant to the concept areas. These new technologies integrate health, lifestyle, and clinical care, and they contextually change the culture of care and training—with more time for engagement, continuity of experience, and dynamic data for decision-making for both patients and clinicians. This poses challenges for users (e.g., keeping up, education/training, skills) and healthcare organizations. Based on the clinical studies and informed by clinical informatics, video, social media, and mobile health, a framework of competencies is proposed with three learner levels (novice/advanced beginner, competent/proficient, advanced/expert). Examples are provided to apply the competencies to care, and suggestions are offered on curricular methodologies, faculty development, and institutional practices (e-culture, professionalism, change). Some academic health centers and health systems may naturally assume that clinicians and systems are adapting, but clinical, technological, and administrative workflow—much less skill development—lags. Competencies need to be discrete, measurable, implemented, and evaluated to ensure the quality of care and integrate missions.
Regulatory Relief to Support Economic Recovery Request for Information (RFI)
The Alliance for Connected Care submitted comments in response to the HHS request for information on the health and economic emergency created by the COVID-19.
The Alliance responded to over 20 recent policy changes with recommendations. We believe some should become permanent and some were only appropriate during the PHE and should cease at its end.
Review our full comments here and below:
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Input for the CONNECT for Health Act of 2021
The Alliance for Connected Care provided feedback on the Senate Telehealth Working Group and Congressional Telehealth Caucus’ request for information (RFI) on
the 117th Congress’ iteration of the Creating Opportunities Now for Necessary and Effective Care Technologies (CONNECT) for Health Act.
The Alliance provided 1) overarching comments about top priorities for telehealth legislation, 2) recommend new provisions for inclusion in the CONNECT package and 3) provide feedback on the continued relevancy of 2019 CONNECT provisions.
Review the Alliance’s comments here and below
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Alliance Joins Letter to Hill in Support of Temporary Extension of DEA Waiver in COVID Relief Package
The $908 Billion Bipartisan Emergency COVID Relief Act of 2020 – While its outcome remains very much in doubt, the $908 Billion bipartisan compromise proposal put forward in the Senate includes a provision to temporarily extend the DEA waiver of the in-person requirement through the end of 2021.
We urge Congress to extend the Drug Enforcement Administration (DEA) waiver of the prior in-person requirement before telemedicine is allowed for prescribing of controlled substances under the Ryan Haight Act through the end of 2021. The DEA has waived this requirement for the duration of the COVID-19 Public Health Emergency (PHE). To provide stability and time for work on a more permanent policy, the waiver should be extended at least until the end of 2021. This provision is included in the $908 billion Bipartisan Emergency COVID Relief Act of 2020.
View the letter
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Digital Health Groups Call on Congress to Extend Telehealth Access
The Alliance for Connected Care, American Telemedicine Association, College of Healthcare Information Management Executives, Connected Health Initiative, eHealth Initiative, Health Innovation Alliance, HIMSS and the PCHAlliance called on Congressional leaders to act to preserve access to telehealth as part of an end of year package.
“While we seek permanent reforms to enable Medicare beneficiaries to continue to access services via telehealth once the COVID-19 public health emergency (PHE) ends, we write today to express our support for provisions, proposed by a bipartisan group of Senators, that would extend temporary telehealth flexibilities until the end of 2021 in an end-of-year package to fund the federal government. We believe this extension is a reasonable policy that will help provide certainty for patients and providers as we work together on permanent reform in 2021.”
“Since many of these needed policies are contingent upon the PHE, millions of Americans risk losing access to vital health care services unless you and your colleagues takes specific actions. Additionally, the continued risk of telehealth flexibilities ending with each subsequent 90-day renewal of the PHE adds additional uncertainty to an already strained health care delivery system. Patients and their health care professionals should not have to worry if they will be able to continue to receive or deliver necessary care.”
Read the Letter to Congressional Leaders on Extending Telehealth Flexbilities 12-11-2020
Milken Institute 2020 Future of Health Summit
Milken Institute 2020 Future of Health Summit, “Realizing the Promise of Telehealth During the Pandemic and Beyond.”
Alliance Executive Director Krista Drobac joined the Milken Institute in a telehealth panel to discuss the rapid shift to telehealth during the COVID-19 pandemic and whether telehealth will allow us to spread access to health services and help foster health equity and narrow the disparities in health outcomes across underserved communities.
Remote Optimization of Guideline-Directed Medical Therapy in Patients With Heart Failure With Reduced Ejection Fraction
Remote Optimization of Guideline-Directed Medical Therapy in Patients With Heart Failure With Reduced Ejection Fraction
Importance: Optimal treatment of heart failure with reduced ejection fraction (HFrEF) is scripted by treatment guidelines, but many eligible patients do not receive guideline-directed medical therapy (GDMT) in clinical practice.
Objective: To determine whether a remote, algorithm-driven, navigator-administered medication optimization program could enhance implementation of GDMT in HFrEF.
Design, setting, and participants: In this case-control study, a population-based sample of patients with HFrEF was offered participation in a quality improvement program directed at GDMT optimization. Treating clinicians in a tertiary academic medical center who were caring for patients with heart failure and an ejection fraction of 40% or less (identified through an electronic health record-based search) were approached for permission to adjust medical therapy according to a sequential titration algorithm modeled on the current American College of Cardiology/American Heart Association heart failure guidelines. Navigators contacted participants by telephone to direct medication adjustment and conduct longitudinal surveillance of laboratory tests, blood pressure, and symptoms under supervision of a pharmacist, nurse practitioner, and heart failure cardiologist. Patients and clinicians declining to participate served as a control group.
Exposures: Navigator-led remote optimization of GDMT compared with usual care.
Main outcomes and measures: Proportion of patients receiving GDMT in the intervention and control groups at 3 months.
Results: Of 1028 eligible patients (mean [SD] values: age, 68 [14] years; ejection fraction, 32% [8%]; and systolic blood pressure, 122 [18] mm Hg; 305 women (30.0%); 892 individuals [86.8%] in New York Heart Association class I and II), 197 (19.2%) participated in the medication optimization program, and 831 (80.8%) continued with usual care as directed by their treating clinicians (585 [56.9%] general cardiologists; 443 [43.1%] heart failure specialists). At 3 months, patients participating in the remote intervention experienced significant increases from baseline in use of renin-angiotensin system antagonists (138 [70.1%] to 170 [86.3%]; P < .001) and β-blockers (152 [77.2%] to 181 [91.9%]; P < .001) but not mineralocorticoid receptor antagonists (51 [25.9%] to 60 [30.5%]; P = .14). Doses for each category of GDMT also increased from baseline in the intervention group. Among the usual-care group, there were no changes from baseline in the proportion of patients receiving GDMT or the dose of GDMT in any category.
Conclusions and relevance: Remote titration of GDMT by navigators using encoded algorithms may represent an efficient, population-level strategy for rapidly closing the gap between guidelines and clinical practice in patients with HFrEF.
Group Letter on DEA Special Telemedicine Registration
The Alliance worked to convene over 80 organizations in a letter to the Drug Enforcement Administration (DEA) calling on the DEA to finalize the special registration for telemedicine. The anticipated registration would enable a practitioner to deliver, distribute, dispense, or prescribe via telemedicine a controlled substance to a patient who has not been medically examined in-person by the prescribing practitioner.
Special registration to prescribe controlled substances through telemedicine was originally called for in the Ryan Haight Act of 2008.
View the letter.
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