Comments & Letters

Legislation by Senators Cortez Masto and Young creates the path to retain patient access to telehealth WASHINGTON D.C. February 7, 2022 – The Alliance for Connected Care (“The Alliance”) is pleased to support the introduction of the bipartisan Telehealth Extension and Evaluation Act (S. 3593) and applauds Senators Cortez Masto (D-NV) and Young (R-IN) for their leadership in drafting this crucial legislation to ensure predictable patient access to telehealth following the end of the public health emergency. “We call on Congress to take up and pass the Telehealth Evaluation and Extension Act this spring, said Alliance for Connected Care [...]

The Alliance for Connected Care submitted a letter to the Senate Finance Committee providing input into the development of bipartisan legislation to enhance behavioral health and substance use disorder care for all Americans. Our letter includes recommendations to answer the following questions: What policies would encourage greater behavioral health care provider participation in these federal programs? What barriers, particularly with respect to the physician and non-physician workforce, prevent patients from accessing needed behavioral health care services? Should federal licensing and scope of practice requirements be modified to reduce barriers for behavioral health care workers seeking to participate in federal [...]

On November 1, the Alliance for Connected Care and nearly 50 stakeholder groups sent a letter to Congress urging lawmakers to make permanent the current regulatory flexibility that allows telehealth and remote care services to be treated as an excepted benefit for certain employees. Including standalone telehealth as an excepted benefit will help ensure hardworking Americans can access high-quality, cost-effective care when and where they need it most, regardless of employment status. Without Congressional action, employers will be unable to offer basic virtual health services to millions of Americans in part-time and seasonal jobs or workers otherwise not participating [...]

ALLIANCE FOR CONNECTED CARE STATEMENT FOR THE RECORD “State of Telehealth: Removing Barriers to Access and Improving Patient Outcomes" The Alliance submitted a letter to the Senate Commerce, Science, and Transportation Committee, Communications, Media, and Broadband Subcommittee on a hearing examining the importance of access to telehealth services, and the role that broadband plays in the public health response. Our statement summarizes the following recommendations: Congress should invest in efforts that support broadband affordability for patients and providers. Congress must continue to coordinate with other federal agencies to ensure improvements are being made to our taxpayer-funded programs, and that [...]

The Alliance for Connected Care provided input into the draft Cures 2.0 legislation released in late June that will build upon the important legacy of the 21st Century Cures Act. A copy of the full Cures 2.0 discussion draft circulating now among lawmakers is available here. A section-by-section summary of the bill is available here. The draft legislation includes several telehealth provisions including: Sec. 402. Strategies to Increase Access to Telehealth under Medicaid and Children’s Health Insurance Program: collaborating with Reps. Blunt Rochester (D-DE) and Burgess (R-TX) to include the Telehealth Improvement for Kids’ Essential Services (TIKES) Act. This policy would [...]

ALLIANCE FOR CONNECTED CARE STATEMENT FOR THE RECORD “COVID-19 Health Care Flexibilities: Perspectives, Experiences, and Lessons Learned” The Alliance submitted a letter to the Senate Finance Committee  on the "COVID-19 Health Care Flexibilities: Perspectives, Experiences, and Lessons Learned.” The Alliance will focus comments on 1) Research and evidence we have gathered thus far; 2) Recommendations for future telehealth expansion that Congress should consider – including steps to ensure equitable access; and 3) Recommendations for telehealth “guardrail” provisions that Congress should consider to prevent fraud, waste and abuse in the health care system. While we prefer the implementation of permanent [...]

ALLIANCE FOR CONNECTED CARE STATEMENT FOR THE RECORD “Charting the Path Forward for Telehealth” The Alliance submitted a letter to the House Ways & Means Committee, Subcommittee on Health on the "Charting the Path Forward for Telehealth.” The Alliance provided: 1) recommendations for telehealth expansions that Congress should consider – including steps to ensure equitable access, 2) comments about telehealth research and evidence, and 3) recommendations for telehealth “guardrail” provisions that Congress could consider, if it is believed they are necessary.

Roughly 20 organizations, including the Alliance for Connected Care have signed a letter asking Health and Human Services Secretary Xavier Becerra to extend Medicare coverage for virtual visits during the PHE and “work on longer-term reforms” that would make connected health a permanent part of the program. Given the ongoing and worsening prediabetes challenges facing seniors, expectations that the PHE will continue throughout 2021, and the cessation of many in-person DPP programs, we believe CMS must act immediately to preserve access to these services. We believe that the Department of Health and Human Services should immediately use its emergency [...]

ALLIANCE FOR CONNECTED CARE STATEMENT FOR THE RECORD “The Future of Telehealth: How COVID-19 is Changing the Delivery of Virtual Care” The Alliance submitted a letter to the House Energy & Commerce Committee, Subcommittee on Health on the "“The Future of Telehealth: How COVID-19 is Changing the Delivery of Virtual Care.” The Alliance provided 1) overarching comments about telehealth research and evidence, 2) recommendations for telehealth expansions that Congress should consider and 3) recommendations for telehealth “guardrail” provisions that Congress could consider. Top Telehealth Priorities These priorities were also outlined in the July 2020 group letter to Congress with [...]

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  

Congress Must Act to Ensure Patients and Providers Don’t Fall Off the “Telehealth Cliff" When Public Health Emergency Ends Today, 340 organizations signed a letter urging Congressional leaders to make telehealth flexibilities created during the COVID-19 pandemic permanent. Those signing this multi-stakeholder letter include national and regional organizations representing a full range of health care stakeholders and all 50 states, the District of Columbia, and Puerto Rico. Congress quickly waived statutory barriers to allow for expanded access to telehealth at the beginning of the COVID-19 pandemic, providing federal agencies with the flexibility to allow healthcare providers to deliver care [...]

The Alliance for Connected Care commented on the Centers for Medicare and Medicaid Services proposed rule on "Medicare and Medicaid Programs; Contract Year 2021 and 2022 Policy and Technical Changes to the Medicare Advantage Program, Medicare Prescription Drug Benefit Program, Medicaid Program, Medicare Cost Plan Program, and Programs of All-Inclusive Care for the Elderly." In our comments, we address four key areas for telehealth and remote patient monitoring: 1) Telehealth for Medicare Advantage network adequacy, 2) telehealth for Special Needs Plans, 3) additional telehealth benefit requirements, and 4) telehealth changes to the medical loss ratio. Please find the full [...]

Comments & Letters 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 [...]

The Alliance for Connected Care provided input into the development of a Cures 2.0 effort that will build upon the important legacy of the 21st Century Cures Act. We look forward to advancing access to digital health technologies.

The Alliance for Connected Care joins 15 other groups to support CMS CY 2020 Physician Fee Schedule and Quality Payment Program proposals on telehealth and remote monitoring.  Our cosigners in the multi-stakeholder letter are AliveCor, American Association for Respiratory Care, American Telemedicine Association, Biocom – Life Science Association of California, Catalia Health, Connected Health Initiative, Diasyst, HIMSS, Kaia, Life365, LifeWire, Pt Pal, Rimidi, UnaliWear and Upside Health. Full Comment Letter: