Dogtown Media Supports Connected Health by Advocating for CMS Home Health Prospective Payment System

mHealth development is rapidly transforming what’s possible in the medical landscape. As this continues, it’s important for all innovators, influencers, and other involved parties to be aligned to ensure healthcare’s future is as bright as it can be.

Recently, Dogtown Media co-signed a letter with 13 other organizations (and counting!) to the Centers for Medicare & Medicaid Services (CMS). The letter provides CMS with our consensus input on its draft payment rates for home health agencies (HHAs) for 2019.

Connecting the Health Community to Catalyze Progress

Connected health technology goes by many names: telehealth, mHealth, remote patient monitoring (RPM), and MedTech are just a few that you’re probably familiar with. But regardless of the jargon and technicalities, they all accomplish the same goals. New paradigms in these areas allow us to reduce hospitalizations, avoid complications, become more efficient, and of course, improve patient outcomes.

We commend and are extremely proud to work with CMS in its efforts to augment care for every American patient through the adoption of these innovations. In our recent letter, we offer up some comments for consideration that could aid CMS in its endeavor to advance the utilization of connected health innovations that improve care and reduce costs.

Comments for the 2019 HH PPS

Although it leverages a form of telecommunication, CMS notes that RPM is not considered a Medicare “telehealth” service as it’s defined in section 1834(m) of the Social Security Act. With this accounted for, it’s important for CMS to not apply the restrictions that fall on telehealth in this section to innovations and practices that are classified as RPM.

We’re also excited about CMS’ proposal to include RPM expenses as administrative costs that are factored into the costs per visit. This means that RPM will be more fairly considered in terms of cost when utilized by an HHA to improve the care planning process.

In the most recent HH PPS draft rule, CMS proposed a definition for RPM as “the collection of physiologic data (for example, ECG, blood pressure, glucose monitoring) digitally stored and/or transmitted by the patient and/or caregiver to the HHA.” This definition should be revised to accurately capture and cover necessary elements of RPM, such as device supply, data collection, data transmittal, and report preparation of results. CMS should also consider using a common definition of RPM across all of its beneficiary programs.

Last but not least, we also voiced our support of measures outlined in the HH PPS draft rule to avoid waste, fraud, and abuse.

A Brighter Future for Connected Healthcare

We’d like to take a moment to applaud the CMS for its continued efforts to improve healthcare by embracing innovation. We’d also like to give a big thanks to ACT, the App Association, for spearheading this letter through its Connected Health Initiative (CHI).

This HH PPS draft rule has great potential to improve patient outcomes across the United States, from Los Angeles to New York. Together with CHI and all other co-signers of this letter, we stand ready to assist CMS in any way we can!