Signal sat down with Brian Scarpelli, Senior Global Policy Counsel at the Connected Health Initiative. CHI is a coalition of industry stakeholders and partners leading efforts to harness the power of technology to improve patient engagement and health outcomes.
As we continue to fight the coronavirus, telehealth and connected health are becoming increasingly important tools to treat patients of all ages facing complex health challenges across the country.
Tell us about CHI’s mission. What does your organization’s day-to-day look like?
CHI is a multi-stakeholder policy and legal advocate dedicated to enhancing the responsible use of connected health technologies that improve health outcomes and reduce costs. Our Steering Committee guides our policy priorities and includes clinicians, healthcare providers and patients.
CHI advances responsible pro-digital health policies and laws in areas including reimbursement and payment, privacy and security, effectiveness and quality assurance, U.S. Food and Drug Administration (FDA) regulation of emerging technologies, health data interoperability, and the rising role of artificial and augmented intelligence (AI) in care delivery.
What’s on the horizon for telehealth and CHI members? How has this changed due to COVID-19?
Since HHS announced the public health emergency (PHE) in March, CHI helps digital health innovations address the challenges posed by COVID-19. New government policies have increased the use of digital health tools and services. (See CMS Administrator announcement.)
While the majority of the allowances made by HHS and other federal agencies are set for the PHE, a few notable allowances are not (e.g., remote physiologic monitoring services can now be furnished to Medicare beneficiaries with acute, as well as chronic, conditions permanently). With the PHE extending through October — and possibly longer–these policies are key. CHI built an allowance tracker of U.S. government policies, publicly accessible on our website.
The PHE allowances are informing digital health policies long-term. Given increased utilization, digital health is here to stay. CHI priorities include:
- Advancing value-based care (e.g., shifting away from the quantity-based ‘fee-for-service’ approach to Medicare payments) through the launch of a new CHI project to develop legislative and regulatory changes needed to bring value to Medicare beneficiaries. We’ve already been able to advance some key provisions in Medicare (e.g., the activation and payment of remote physiologic monitoring codes in Part B). However, much work remains to be done.
- Developing a new policy approach focused on greater use of digital health technology to identify and mitigate health disparities, particularly as it relates to resource coordination, policy advocacy, research, and education. This is in partnership with the Consumer Technology Association.
- Continued AI advocacy and education in healthcare. Building on our general health AI policy principles and a state Medicaid/CHIP policy paper, CHI will release “good machine learning practices” for the FDA as its approach to AI evolves.
Can you share an example of a telehealth experience or innovation that might not have happened without COVID-19?
Each of the CHI Steering Committee’s members have stepped up in big ways to address the ongoing COVID-19 crisis. As an example, the University of Virginia’s Karen S. Rhueban Center for Telehealth, already a long-time telehealth innovator, provided telehealth services related to COVID-19 and regular medical care for several long-term care facilities. Long-term care facilities are particularly hard hit by COVID-19, and through this partnership, UVA helped mitigate the spread of the virus within these facilities while getting patients the care they need.
How has telehealth improved access to care for patients?
First, I should note that the terminology can cause some issues because in Medicare, “telehealth” means a select set of live voice and video calls and does not include other asynchronous modalities like remote monitoring. But even if we use this limited definition, its impact has been immense in its limited deployments already, and even more so during the PHE. For example, over 3 million beneficiaries have received telehealth services via traditional telephone alone during the PHE, as of a few months ago.
More broadly, data and clinical evidence from a variety of use cases continue to demonstrate how the connected health technologies available today—whether called “telehealth,” “mHealth,” “store and forward,” “remote patient monitoring,” “remote physiologic monitoring,” “communication technology-based services,” or other similar terms—improve patient care, prevent hospitalizations, reduce complications, and improve patient engagement, particularly for the chronically ill. Connected health tools, including wireless health products, mobile medical devices, software as a medical devices, mobile medical apps, and cloud-based portals and dashboards, have fundamentally improved and transformed American healthcare (see, for example, this CHI collection of studies), and will continue to do so.
Despite the proven benefits of connected health technology to the American healthcare system, statutory restrictions and CMS regulatory-level policy decisions, among other constraints, inhibit the use of these solutions. As a result, there was low utilization of digital health innovations prior to the COVID-19 public health emergency (PHE), despite the ability to drastically improve beneficiary outcomes and generate immense cost savings. CHI has made major inroads in changing policy and law to better enable the responsible deployment of these new technologies, and there are great experiences and data being gained through programs like the Federal Communications Commission’s COVID-19 grant program. But again, there is much work to be done!
Do you have any predictions about the future of telehealth and what will be needed to better meet coronavirus care needs – and beyond?
COVID-19 accelerated digital health across the US healthcare ecosystem. Overdue reform efforts, informed by experiences during the PHE, will open the door to modernizing policies to improve care through technology. The questions rest in the specifics, and what key changes can be made to allow continued use not only through expanded payments and subsidies, but also reduced burdens associated with legacy statutory provisions in areas like privacy protections under HIPAA and anti-fraud and anti-abuse measures.
HHS rules addressing information blocking have been put into place at an important time. Interoperability and patient access to health information prevent timely and informed care coordination and decision-making. Further, electronic health information and educational resources are critical tools that empower and engage patients in their care. A truly interoperable eCare system includes patient engagement facilitated by store-and-forward technologies (ranging from connected medical devices to general wellness products) with open application programming interfaces (APIs) that allow the safe and secure introduction of patient-generated health data (PGHD) into electronic health records (EHRs). Data stored in standardized and structured formats with interoperability facilitated by APIs provides analytics as well as near real-time alerting capabilities. The use of platforms for data streams from multiple and diverse sources will improve the healthcare sector, helping to eliminate information silos, data blocking, and deficient patient engagement. Interoperability must not only happen between providers, but also between remote patient monitoring (RPM) products, medical devices, and EHRs. The COVID-19 public health emergency has highlighted the need for streamlined information flows between patients and those in the care continuum value chain. Enforcement of the information blocking rules should begin on schedule and should be enforced.
CHI is also working on another important front that many may not think of — the development of codes through the American Medical Association’s (AMA) Current Procedural Terminology process. CHI is an appointed member of the AMA Digital Medicine Payment Advisory Group (DMPAG), an initiative bringing together a diverse cross-section of 15 nationally recognized experts who identify barriers to digital medicine adoption and propose comprehensive solutions revolving around coding, payment, coverage, and more. The DMPAG, for example, created the new remote physiologic monitoring codes, a new code for using an AI tool for diabetic retinopathy, and others –and has many new solutions in the works that will be brought forward soon. It’s probably not discussed enough, but the DMPAG is going to be key to evolving the entire healthcare system in America.
Do you see any policy or regulatory challenges that need to be addressed to facilitate/ensure telehealth use for the long-term?
There’s a wide range of policy changes needed to realize the benefits of digital health technologies. CHI has initiatives for each of these areas that we’re always seeking new partners and collaborators for these efforts. A few long-term priorities:
- Payment is the central issue (whether a provider is subject to Medicare requirements or not) and must evolve to responsibly integrate with advanced technologies. We’re prioritizing payment through our work with the AMA DMPAG as well as through our advocacy to Congress and CMS. But we must identify the best ways to advance value-based care and move away from today’s legacy health systems that incentivize quantity over quality.
- Advancing responsible health data stewardship and privacy throughout the continuum of care. No data is more personal to Americans than their health data. CHI members acknowledge that significant threats to Americans’ most sensitive data continue to evolve and put extensive resources into ensuring the security and privacy of health data to earn the trust of consumers, hospital systems, and providers. Ultimately, CHI supports and leads work development of a new cross-sectoral privacy framework by Congress in the form of a general privacy bill that is intended to result in general privacy legislation.
- Given the varied applications of AI systems in health care such as research, health administration and operations, population health, practice delivery improvement, and direct clinical care, incentives must be in place. We must encourage investment in building infrastructure, preparing personnel and training, as well as developing, validating, and maintaining AI systems with an eye toward ensuring value. Payment policies must incentivize a pathway for the voluntary adoption and integration of AI systems into clinical practice as well as other applications under existing payment models.