Connected Health Initiative (CHI) Check-In – Halfway Through 2017!

2017 has been a busy year for the Connected Health Initiative (CHI). As we reflect on the first half of the year, we’ve pulled together highlights of what we have done, and what lies ahead in our mission to foster a robust connected health ecosystem. No post could fully encapsulate all the work that we do, but below we provide a broad outline of our work and accomplishments this year.

CHI remains a leading coalition of industry stakeholders seeking to harness the power of technology to improve patient outcomes and reduce costs. While most industries are quickly becoming more interconnected through mobile technology and sensors, we sadly cannot say the same for the American healthcare system, particularly the Medicare and Medicaid programs. We continue advocating for an environment that will modernize our healthcare system and bring more connected health technologies to more Americans in more places. Here’s a look at what we have accomplished, and look forward to, in 2017.

2017 Snapshot

On the Legislative Front

The CONNECT for Health Act

On May 3rd, the Senate reintroduced the bipartisan CONNECT for Health Act. The bill would amend Title XVIII of the Social Security Act to expand Medicare beneficiary access to telehealth services. Moreover, the bill goes a long way toward integrating remote monitoring (RM) of patient generated health data (PGHD) into Medicare services, which will increasingly be a critical aspect of any modern healthcare system. To encourage a successful passage through Congress, CHI wrote a letter to the CONNECT for Health cosponsors to express support for the bill. Our letter emphasized the demonstrated benefits of telehealth and RM solutions, which include improved care, reduced hospitalizations, avoidance of complications, and improved satisfaction, especially for patients suffering from a chronic illness. On May 19th, Representatives Black (R-TN-6), Harper (R-MS-3), Thompson (D-CA-5), and Welch (D-VT-at large) introduced the CONNECT for Health Act in the House, for which CHI also provided a letter of support. We continue working to move this landmark bill forward, either as standalone legislation or as part of a larger healthcare package.

CHRONIC Care Act

CHI has supported the years of work by the Senate Finance Committee’s bipartisan Chronic Care Working Group, and their subsequent introduction of the CHRONIC Care Act. We continue to advocate strongly for this bill’s introduction in the House. While the CHRONIC Care Act does not include all the CONNECT for Health Act’s provisions, it does incorporate key components that overcome the backwards-facing legacy restrictions of Section 1834(m) of the Social Security Act, which defines telehealth for the Medicare program. Given its reasonable score from the Congressional Budget Office (CBO), the Senate’s CHRONIC Care Act has a promising trajectory. CHI wrote a support letter to the Senate Finance Committee, in which we described the essential nature of mobile technology and third-party apps to expand telehealth services and provide patients with chronic illnesses greater access to these life-changing services. We also emphasized that a vibrant app economy and a strong wireless infrastructure are necessary conditions for the growth of telemedicine and RM. CHI is encouraged by the progress made so far, but there is much more work to do to get this bill across the finish line.

Preventative Health Savings Act

A common roadblock to the passage of a bill is its CBO score.  However, the Preventative Health Savings Act would reform the way in which the CBO calculates its score for health-related bills by including preventative health savings. In the past, these savings would otherwise be excluded. Working with Representatives Burgess (R-TX-26) and DeGette (D-CO-1), CHI played a leading role in the bill’s June re-introduction. We also joined a multi-association letter supporting this bill and continue to work to advance this important legislation.

On the Regulatory Front

CHI has been at the forefront of promoting connected health capabilities to key government agencies, including the Department of Health and Human Services (HHS). Here are examples of the agencies with which we have worked, and issues we have spearheaded:

HHS’ Center for Medicare and Medicaid Services (CMS)

In April, CHI submitted a letter and supplemental chart to HHS Secretary Tom Price to outline regulations inhibiting the growth of telehealth and telemedicine opportunities. The letter explained how the Secretary can address these concerns without congressional action, either under existing authority, or using well-established waiver authority. For example, HHS can readily address the range of reimbursement options for telehealth and remote monitoring practices within the Alternative Payment Models, such as Medicare Advantage. This measure alone would provide much-needed clarity from the HHS Office of the Inspector General regarding the application of anti-kickback laws for caregivers who want to help their patients utilize the power of mobile technology.

Through the Medicare and CHIP Reauthorization Act (MACRA), HHS can now leverage telehealth and RM to provide Medicare services. Recently, CHI has provided recommendations to CMS on its Merit-based Incentive Payment System’s Improvement Activities and Advancing Care Information Measures, alongside comments to the National Quality Forum regarding its draft telehealth quality measurement framework. In the latter half of 2017, we look forward to reviewing and providing input on the latest draft MACRA rules and the CY 2018 Physician Fee Schedule, which will each provide crucial rulemakings for the current and future Medicare systems.

We believe HHS has plenty of tools in its toolbox to promote telehealth and RM, which have been proven to bring down costs for Medicare beneficiaries and their caregivers. CHI is committed to work with HHS staff on ways to improve the American healthcare system, based on its consensus recommendations.   

HHS’ Office of the National Coordinator for Health Information Technology (ONC)

CHI continues to work with ONC during its political and leadership transition. In May, we submitted comments to ONC in response to its white paper on the PGHD framework it developed with Accenture. Our comments outlined our concerns with the methodology used in the framework and encouraged ONC to broaden its pool of input before issuing formal recommendations. Furthermore, we provided guidance to ONC by contributing a series of important industry and academic pilots to stress the importance of a strong, yet flexible, PGHD framework. These pilots represent the wealth of information ONC has at its disposal that prove the important role of telehealth and RM in both preventative and administrative monitoring, and make the case that ONC need not only rely on Accenture’s study. We believe there must be sensible and concrete policy prescriptions to achieve a sustainable PGHD framework, and we note that their framework report does not, but should, specify how ONC will operate in this space moving forward.

HHS’ Food and Drug Administration (FDA)

The FDA is a crucial agency for connected health innovators who design or manufacture health products. CHI has a long history of working with the FDA to ease its lengthy and expensive approval process, and does so by advocating for regulatory reform and developing regulatory guidance documents. We were pleased by the FDA’s new effort to streamline the approval of digital health tools, as well as the implementation of its pilot program for the use of third-party certifications. This effort built on our work with FDA over the last few years, and we will continue to engage on this issue and work to ensure companies can navigate the FDA approval process expeditiously.

The Federal Communications Commission (FCC)

The benefits of RM and telehealth services cannot be realized without a robust wireline and wireless communications infrastructure to transfer data efficiently. This is precisely why the FCC’s Connect2Health Task Force requested input on the ways broadband infrastructure could assist the healthcare industry. CHI provided comments on these issues, ultimately advocating for faster, stronger networks to accommodate the emerging data-driven healthcare ecosystem. We applauded the FCC chairman for making next generation 5G infrastructure a primary policy objective and encourage the Commission to take every opportunity available to allow for more 5G development. For example, we advocated for the utilization of TV White Spaces, which are unused or underutilized television broadcast frequencies, to bring greater connectivity to communities across the country, and support connected health solutions in the most rural areas of the United States.

These are just highlights of the work we have done in the first half of 2017. We will continue to “pound the pavement” to bring telehealth solutions to more Americans across the country. We welcome your interest and partnership in advancing these important healthcare priorities.