The Alliance for Connected Care provided feedback to HHS on proposed rules revising safe-harbors under the Anti-Kickback Statute and Civil Monetary Penalty rules on beneficiary inducements. The Alliance focused its comments on four priority areas for telehealth and remote patient monitoring in the proposed rule:
- Request for comment on the possible exclusion of health technology companies from value-based safe harbors
- Implementation of the statutory exception for telehealth technologies for in-home dialysis as passed by Congress
- New opportunity to protect arrangements involving telehealth and remote patient monitoring under the care coordination safe harbor
- New safe harbor for patient engagement and support that could include telehealth and remote patient monitoring services
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