Regulatory Outlook for Telehealth

In this episode of TD Cowen’s FutureHealth Podcast Series, Krista Drobac, Executive Director of the Alliance for Connected Care, a telehealth industry trade group speaks with Charles Rhyee, Health Care Technology & Distribution Analyst. 

They discuss the regulatory outlook for telehealth, including work towards extending current federal rules to expand access to telehealth during the current public health emergency and state level efforts on expanding medical licensure flexibilities. In addition, they also talk about the application of telehealth as more care, in general, is being delivered in the home and the needed regulatory changes required to enable that shift.

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Transcript

Announcer:

Welcome to Cowen Insights, a space that brings leading thinkers together to share insights and ideas shaping the world around us. Join us as we converse with the top minds who are influencing our global sectors.

Charles Rhyee:

Hello, my name is Charles Rhyee, Cowen’s healthcare technology analyst, and welcome to the Cowen Future Health Podcast. Today’s podcast is part of our monthly series that continues Cowen’s efforts to bring together thought leaders, innovators, and investors, to discuss how the convergence of healthcare technology and consumerism is changing the way we look at health, healthcare and the healthcare system. In hosting with me today, I’m joined by my colleague, Eric Assaraf from Cowen’s Washington Research Group. And in this episode, we’ll be discussing the regulatory outlook for telehealth, including work towards extending current federal rules, expanding access to telehealth during the current public health, health emergency, and state level efforts on expanding medical licensure flexibilities.

Charles Rhyee:

In addition, we’ll also talk about the application of telehealth as more care in general as being delivered in the home and the needed regulatory changes required to enable that shift. And to discuss these topics. We are joined by Krista Drobac, Executive Director of the Alliance for Connected Care, an industry trade group dedicated to ensuring that all patients are able to realize the benefits of telehealth and virtual care. Krista has over 20 years of experience in federal and state government, including Director of the Health Division at the National Governor’s Association’s Center for Best Practices, Senior Advisor at the Center for Medicare and Medicaid Services and Health Advisor to two US senators on Capitol Hill. Krista. Thanks for being with us today.

Krista Drobac:

Thank you so much for having me.

Charles Rhyee:

Thanks and Krista, maybe to start, can you tell us more about your work at Alliance for Connected Care?

Krista Drobac:

Yes, absolutely. The Alliance for Connected Care started eight years ago. It’s a 501(c)(6), which means we are a lobbying organization. It is made up of employers, health systems, technology companies. We have Amazon, CBS, Walmart, Intel, and then we have some of the largest and most progressive hospital systems in the country, Inner Mountain, Ascension, Stanford, Johns Hopkins, MedStar, and then some of the vendors, Amwell, MDLIVE, for example. And most importantly, we have a very robust advisory committee that is made up of patient groups like MS, Parkinson’s, ALS and also provider groups like physician’s assistants, primary care providers and nurses. So we have a very broad group of perspectives. When we go to Capitol Hill and say we’ve managed to agree on something within our coalition, we’re confident in saying that it is a consensus position.

Charles Rhyee:

And so a lot of your work then is really voicing the … Providing voice to the industry in terms of where your constituency would like telehealth to move towards. And it seems like this is the time as one of the few positive is to come out of the pandemic has been really the emergence of telehealth. Obviously it’s been something that had been slowly gaining traction prior to COVID, but the pandemic has really moved it into the mainstream. Certainly a key to that we’ve seen actions take by Congress and CMS in the early days in the pandemic to expand access telehealth. Maybe can you start by reminding us some of the key changes that were enacted in the early part of last year?

Krista Drobac:

Yeah. When you say that telehealth started gaining traction, it really was mainly in the employer market prior to the pandemic. And we were battling it out in Congress, to get coverage in Medicare. And we kept saying if people just tried telehealth, then we would have a constituency who would be up asking Congress for coverage in Medicare, because they would want to continue it. And so as soon as the pandemic came, we suddenly had the experience of telemedicine being offered in Medicare. The reason why it was so important is it really rounds out the rest of the market. It’s impossible to have major changes in the way that people receive care if you don’t have all markets. So we needed Medicare and Medicaid to join the employer market, in order for providers to start changing their workflows and for telehealth to really become an embedded part of the healthcare system.

Krista Drobac:

What happened in March of 2020 was remarkable. Congress passed in the very first COVID response bill, the ability for CMS to waive restrictions in Medicare. People no longer had to be in a rural area and they no longer had to be in an institution. You could receive telemedicine anywhere from a provider and they actually changed the rules around a provider address. The provider could be at home and submit a claim to CMS as if they were in their office. That just created exponential growth in the use of telehealth. Of course, people didn’t want to be in person anyway. So we now have a whole group of seniors who have tried telehealth and it becomes difficult for providers because if Congress doesn’t keep these flexibilities in place, providers still have patients that want to keep telehealth in place. So it creates a conundrum for us all. But that’s one of the reasons we’re working so hard to make sure that Congress keeps these flexibilities around.

Charles Rhyee:

And maybe can you highlight some of the key ones? Obviously the extension within Medicare … Sorry, access within Medicare, but there were a few others along the way as well. Maybe just highlight some of those.

Krista Drobac:

Yes. So not only did coverage change in Medicare, but practitioners that could provide telehealth also changed. So all of a sudden PT, OT, speech therapy, those things could also be offered through telehealth. You could prescribe controlled substances use for behavioral health through telehealth. One of the big use cases in the pandemic has been the need for mental health services. You could now prescribe mental health drugs that are classified as controlled substances. You can do that over telehealth. We have 35 million Americans in this country with health savings accounts. In the employer market it’s very frequent that people have a high deductible plan coupled with a health savings account.

Krista Drobac:

The IRS does not allow for seller coverage for telehealth, if you hold an HSA. There was a provision allowing for first dollar coverage for telehealth, if you have an HSA. So employers were able to provide telemedicine services on a first dollar basis to all of their employees, not just their employees that had an HMO or a PPO. So those are the really big ones that happened because of the pandemic. I mean, I could go on and on about Medicare, but the main provisions were that you could suddenly receive telehealth anywhere.

Eric Assaraf:

Hey Krista, Eric Assaraf here. Thanks for being here. So most of the telehealth flexibilities will end when the public health emergency is declared over. We know that the PHE will at least go through year end, and then likely extended in three month increments after that. Can you remind us which policies are related to the PHE and which ones are not, and what the group is doing to extend those changes?

Krista Drobac:

Yes. If you had told me in mid 2020 that we would be hopeful to get an extension, I would’ve been surprised. I was thinking we would have permanent change because how do you go back from this? But we are currently seeking extensions of two years and most of them can be done at the time that the PHE expires, but there is one that expires at the end of this year, it had a hard stop in the statute and that is the HSA provision. It’s been challenging for employers because they have open enrollment coming up and they already have developed their benefit packages for 2022 and they aren’t sure if the HSA provision is going to be expanded. If you are an HSA holder and you have been using telehealth services in 2021, it’s possible that you have a benefit package that seemingly covers it.

Krista Drobac:

But in fact, you won’t have access to that if Congress doesn’t extend it. So we’re trying to get an extension of the HSA provisions before the end of this year, the rest of it is dependent on the PHE and Congress … The Congressional Budget Office has said that their estimation is that the PHE will stay in place until July of 2022. In some ways it hurt us on lobbying because Capitol Hill will say, “Oh, well, we have six more months to deal with that. We’re not going to deal with it before the end of the year.” And what we’ve been saying is, “You need to deal with this at the end, by the end of the year, because we may not have vehicles next year. It is an election year. Things get a lot more complicated and also you need something called an offset to pay for these things.”

Krista Drobac:

And in the CBO, regardless of how much data we give them, still believes that telehealth costs more than in person care. They will put what’s called a score on it and we need those offsets. So we’ve been pushing hard for the end of this year for a two year extension until the end of 2023. Now CMS does have a small amount of authority. The statute is fairly restrictive, but they do have the authority to add codes. They added a whole new category of codes, category three codes, and they have said, “We’re going to keep these codes in place until the end of 2023 and you stakeholders have to prove to us that these codes are worthy of being made permanent for telehealth use.”

Krista Drobac:

Congress is interested in aligning their timing with CMS. So that makes us think that any extension that happens will happen, extending it until the end of 2023. And we have a bill being developed in the Senate and there are already bills in the house on both the HSA topic and the Medicare topic. There will not be an extension of telehealth in the reconciliation package. This is a bipartisan bill. As long as there are still offsets left over after reconciliation happens, we will have a telehealth bill either at the end of this year or Q1 of 2022.

Eric Assaraf:

And I think you mentioned there’s a few bipartisan, bicameral bills for permanent telehealth expansion, including Telehealth Modernization Act and Connect For Health. Are those still the main vehicles that you guys are looking at? You mentioned not reconciliation, but what other vehicle could it go on? A spending or something else?

Krista Drobac:

I think everybody has pivoted to an extension right now. The main reason that we are not having a robust discussion about permanent expansion is the perceptions of fraud and cost. Congress has a perception that somehow telemedicine is uniquely subject to fraud. The Office of the Inspector General at HHS has taken up six studies of telemedicine, three of which have come out and all have been very positive. We have been telling Capitol Hill the OIG is going to be the final arbiter of if there’s fraud or not. We can’t just like perceive it and we have to actually look at the data. And in the past tele-fraud, there’s been tele-fraud, which is actually telemarketing fraud. So it was illegal solicitation of Medicare beneficiaries for purposes of over billing durable medical appointment. It has nothing to do with telemedicine, but that those tele-fraud headlines, which tend to be hyperbolic headlines coming out of the Department of Justice, have given Capitol Hill a perception that there’s telemedicine fraud.

Krista Drobac:

What we really needed is the reports from OIG, looking at who billed telehealth? Were there false claims related specifically to telehealth? What we found so far is there’s been an increase in access, there’s been no additional new fraud because of telehealth. And so we have to, as advocates, spread the message around the hill and send those OIG reports saying OIG is not finding additional fraud. The second issue that we have to battle the perceptions around is cost, that somehow telehealth costs more than in-person care. There’s this longstanding conventional wisdom that seniors will get an in-person visit and also get a telemedicine visit for the same condition or that a senior would not otherwise have sought care. But because telehealth is so convenient and easy that they will seek care.

Krista Drobac:

Now, we always argue that if that’s the case, maybe it’s actually better that they sought care early in their condition because otherwise it gets worse and it could potentially cost more. So we have been in fact, on our website ConnectWithCare.org, we have data from the health systems that we’ve been collecting, showing that there is a substitution effect. Telemedicine is substituting for in-person care, when in-person care goes up, telemedicine goes down and you can see that from the various surges in COVID that early on telehealth was very high, but as people started coming back, telehealth started going down. There was not an overall increase in utilization over what was expected utilization for 2021, or 2020 for that matter. So we, as advocates have to do a lot of education on cost. That brings me to the extension. This is why we have pivoted to an extension, because what we’ve said to the hill is, “Give us another year and a half to two years and we will show you that your worries about cost and your worries about fraud are not rooted in the data.”

Krista Drobac:

And so, while I would love to be talking about permanent authorization of telemedicine and Medicare, or as a first seller coverage for HSA, until we have the data, we’re not going to get that. The Telehealth Modernization Act is our preferred bill. Both of them are principal sponsored by Senator Brian Schatz from Hawaii, but the Telemedicine Modernization Act was written during the pandemic. It was written with the doors blown off the place, you know? We like TMA a lot. The Connect bill is a legacy bill. It was first introduced in 2016. It’s been around a long time. They certainly made changes to it to make it better.

Krista Drobac:

But the Telemedicine Modernization Act just basically says a patient can be anywhere. Whereas the Connect Act still requires you to be in a particular place, defined by law. And we don’t think that you can really define someone’s home because they could be in their driveway or at their neighbor’s house. And so the compliance officers don’t necessarily like home as a place that you can accept telehealth. So sorry for the long answer.

Eric Assaraf:

No, that’s fine. Maybe switching to the state level, your group is spearheading a campaign in which 230 organizations sent letters to all 50 state governors asking them to extend licensure flexibilities for telehealth. So what’s the key issue here and have you gained any traction on that effort?

Krista Drobac:

Yes. If you want to practice in a state, you have to be licensed in a state where the patient is located. So I’m going to talk about doctors just as an example, but really this applies to nurses, physician assistants, physical therapists. I mean everyone. So you take a national exam, you do your boards, but you still have to be licensed in the state where the patient is located. We think this is an artificial barrier. We think that if you have a licensed and are in good standing with a medical board and you’ve done your continuing medical education, you’ve paid all your fees to have a license that you shouldn’t necessarily be barred from treating patients across the country. When the pandemic hit all 50 states waived some form of licensure to allow other providers to come into their state. Today, 27 of those states have had expirations to their flexibilities.

Krista Drobac:

When in Virginia it expired, one of our members, Johns Hopkins, had to reschedule all of these patients and tell them that they have to drive to Baltimore to get care. There are real examples because of these flexibilities of patient accessing care across state lines that now can’t do that. I heard a story the other day of a guy who actually drove across the state line to do a telehealth visit in his car. Because of these artificial barriers. The letter that 230 groups sent to all 50 governors basically asked them to reinstate or continue their license or flexibilities to allow for providers to practice across state lines. We have a broader effort going on and in the form of a piece of legislation that would create a national compact much like what we have with the driver’s license compact, for example, that would allow for states to voluntarily opt in to a compact that would allow providers to cross state lines.

Krista Drobac:

We’re also working at the regional level to create regional free zones where you could practice across state lines in a particular region. It does seem to be in these early stages, easier to pass regional compacts because people live regionally. I live in the DC, Maryland, Virginia area and we go between those three jurisdictions all the time. So it’s a little easier for people to get their heads around a Virginia doctor practicing in Maryland than maybe like a doctor from Minnesota practicing in Virginia, for example. So we’re taking the national and a regional approach to this issue.

Charles Rhyee:

Krista, haven’t many states already enacted these interstate compacts? I think like the Mountain West states, a bunch of them have an agreement among themselves. I thought that was a process that had already been underway here.

Krista Drobac:

There are compacts in other areas, but not in medical and clinical licensing. I mean, if you think about Oregon, there was a bill in Oregon that would’ve allowed an EMT and an ambulance to take a patient across state lines if the hospital was closer. If you’re in a very rural part of Oregon and you’re picking up a patient and there’s a closer hospital that’s in another state, they wanted to be a able to take them there. And that bill failed. I mean, there’s like iron clad licensing boards that don’t want to change the way that things work today.

Krista Drobac:

There are some compacts in place. We like the nurses compact, which is only RNs. It doesn’t cover advanced practice nurses, like NTs, just RNs. That one does have mutual recognition or reciprocity. So that’s what we’re looking for is mutually recognized licenses. You still have to have a license, a nurse compact license, but you can practice in any compact state. The other compacts don’t really have mutual recognition. There is a doctor compact, and you still have to be licensed in the state. It’s supposed to expedite your license, but it doesn’t really work, which is why our members are really all in on trying to create true license reportability.

Charles Rhyee:

This reminds me a little bit, I think it was several years ago, Texas, right? I think Texas State Medical Board was really trying to prevent any telehealth coming into the state. And I think it was being challenged on grounds of being anti competitive. I think in the end, Texas stepped stepped back from that challenge. I don’t know if you recall that.

Krista Drobac:

Yes, the Teladoc case.

Charles Rhyee:

Yeah. Is that the main thrust? Because it just really strikes to your point about being arbitrary. It’s really about anti competition. I mean, is that the grounds?

Krista Drobac:

Yes. That’s what we think. I’ll give you another example. I think it was 2014. The FTC went all the way to the Supreme Court against the North Carolina Dental Board because the North Carolina dentists stepped in and said that tanning booths couldn’t offer teeth whitening. And so the FTC basically said the dentists are regulating their own market. There’s nothing particularly advanced about teeth whitening and tanning booths can do it just fine. And so the dental boards were acting in an anti competitive way. What the Supreme Court ruling in effect did, was say that state legislatures have to oversee the medical boards and that was supposed to be the check on their power, but in practice, it doesn’t really work that way in our experience. It’s mainly, almost like a delegation of the power of the state legislature to the medical board.

Charles Rhyee:

I see.

Eric Assaraf:

On this topic of licensure, is this an area that Congress could get involved or is it really up to the state governments to deal with this issue?

Krista Drobac:

Congress would have to preempt state law and honestly, no one … I mean, there’s going to be no appetite for that, but I also don’t think that there is a federal agency that necessarily could take on licensure. Back in 2013, there was a bill that would’ve given the Department of Labor the job of overseeing licensure. I think most of probably realize that healthcare markets are local. And it does make sense for states to have a role in making sure that the providers in their states are not putting patients in danger, for example. So from our perspective, it is a state issue and should remain a state issue, but we need a national infrastructure so that patients can receive care and providers can provide care across state lines. It really is like for example, adopting a child, it used to be that each state had different rules around adoption so that you may not necessarily have the same rules if you have an adopted child, if you go to a different state. Well, that doesn’t really make any sense.

Krista Drobac:

There is a compact among states for adoption. There’s a compact for driver’s licenses. There’s lots of examples of agreements across states where they honor the licenses or laws of other states. So our bill that we’re working to get introduced in Congress has HHS with great engagement from stakeholders and rule and comment, open comment to create a compact that states could voluntarily join. They would create the national infrastructure that then states could decide if they want to join it. And one of the reasons why we so strongly that HHS be the drafter of the compact is because we need to put an American citizen, the consumer, at the center of the decisions about what this infrastructure is going to look like and not necessarily the parochial interests of some licensing board and all of the licensing compacts that we have in place today were drafted by licensing boards.

Krista Drobac:

We want to take this out of the hands of the licensing board and make it about the consumer. Think about the parent whose child just got diagnosed with epilepsy that needs to load their child in a car and drive three states over to go see a specialist or the patient who had surgery in Baltimore, but lives in Richmond and has to drive back to Baltimore to get follow up care. There’s plenty of use cases for cross state lines care. And we need to think about those people and the access to care rather than market share or licensing revenue from licensing fees or any of those other issues.

Charles Rhyee:

Maybe just follow up there, what do you think are the prospects then for we’re getting that bill introduced and hopefully getting it passed sometime next year? Any thoughts there?

Krista Drobac:

I think this is probably a longer road. We would not be where we are today without the pandemic. So I would say this fast forwarded us five or six years. We are getting a lot more attention to this issue, especially because the flexibilities are expiring at the state level. And patients actually feel real impacts from not being able to go across state lines, whereas before it was just a way of life to drive to another state for care. So those things are contributing, I think, to an acceleration of getting something done. But our main problem here is the narrative. To us, it’s really not about where the provider is disciplined. Because as soon as you start talking about this in the state legislature, they say, “Well, what is the medical board think? And how is the provider going to be disciplined?”

Krista Drobac:

And we really get down into the weeds about that. What we want people to be asking is how do we make things easier for families and patients? And what are the consequences of keeping these barriers up? Because we think that it’s not that hard to figure out how to do coordination among medical boards for purposes of discipline and less than 1% of doctors are disciplined every year. And yet thousands of patients could be accessing care across state lines. We’re working now and just changing the narrative and lot more attention on this topic.

Charles Rhyee:

Great. Before we move to the next topic I wanted to follow up, you said at the beginning, at this time last year, if we were just talking about extensions, you wouldn’t have believed it. You thought a lot of these were going to be made permanent. And I think there’s generally this perception that Congress won’t let these flexibilities end. You alluded to the fact that there are some concerns in Congress, like how serious should people be that … I’m sorry, how seriously concerned should people be that these extensions could end and these rules revert back to how they were almost on a dime?

Krista Drobac:

I wrote a blog about this. I got tired of hearing people say, “Oh, the genie’s out of the bottle” or, “The toothpaste can’t be put back into the tube.” They like wave their hands in the air and say, “Well, there’s just no way Congress could do this.” But in fact, misperceptions about telehealth have persisted. It’s so surprising to me. And so let me give you an example, what I was saying about tele-fraud being about durable medical appointment. We just complained mightily to the Office of the Inspector General about the misleading headlines around tele-fraud. And we said, “You are doing damage on the hill to our efforts to make sure that seniors can get ongoing access to telehealth by putting out these hyperbolic headlines. And it’s confusing. So we need you to clarify this.” So lo and behold, a Friday afternoon, the Office of the Inspector General releases a statement in part saying, We want to be clear that we’re not talking about telemedicine fraud, we’re talking about DME fraud.”

Krista Drobac:

And so of course we all like said, “Hurray.”. Then two days later, two business days later on Tuesday, there was a hearing in the House Energy and Commerce Committee where almost every opening statement of a member of Congress talked about telemedicine fraud. And so it’s like the headline grabbed everyone’s attention, created conventional wisdom. And now we’re up there, member by member, trying to educate staffers on the fact that we don’t have a fraud problem with telehealth. So I think they feel an obligation to the taxpayers to make sure that we’re not blowing the Medicare budget by allowing telehealth.

Krista Drobac:

That is their job. And it’s our job to show them that we’re not going to create a budgetary disaster by allowing virtual care and Medicare to go on in perpetuity. And so they are taking a pause, which I understand, but we probably need to get this data up to them and get them convinced pretty quickly, because we really have basically until July of next year to make this change. So I don’t know. I put us, I guess, at this point, like 60/40 that it gets done.

Charles Rhyee:

Wow. I would’ve assumed a little higher. I guess I fell into the other conventional wisdom that they won’t let it end, but let’s move on then. For the sake of this conversation, let’s assume that we do get the exchanges. Because I do think for all the providers that we speak with I think a lot of them are embracing telehealth as part of their business and how they deliver care to patients. And as it really becomes that integral part of care we hear it a lot from companies as they talk about how they are incorporating that virtual care and they think about care delivery, particularly as they extend their reach into patient’s homes. And I know that’s a project that you’ve been working on as well. Can you tell us more about that?

Krista Drobac:

Yes. Back in mid 2020, when we had eternal optimism, we started thinking, “Well, what happens when we have permanent telemedicine coverage, including remote patient monitoring?” We’d been working so long to get coverage of the tools, but we hadn’t necessarily thought deeply about the care models that those tools fit into. And we started these conversations and realized this is a whole different work stream because most care for patients is going to be integrated. It’s going to be partially virtual and partially in person. And most patients want to stay home. They want to receive care in the home. So how do we combine the tools that would enable that with the policy changes that make it possible? We launched a coalition called Moving Health Home. Some of the founding members are also members of the Alliance for Connected Care. We now are at 25 members. Initially when we launched, we patted ourselves on the back because we thought, “Oh, we have such a diverse originating group of founders.”

Krista Drobac:

We thought, “Oh, well, we’ve got in-home primary care. And we’ve got health systems. We’ve got technology providers.” And what we realized was we were missing huge out of healthcare and we needed policy in all of those areas. So now we have home infusion, home dialysis, in-home diagnostics, in-home labs, and we need all of those pieces and policy changes in all of those areas in order to truly move healthcare into the home. And we’re not saying that this is at the detriment of institutions. We just want this to be an option for patients.

Krista Drobac:

We have few work streams. We have a hospital at home work stream. There was a waiver during the pandemic. There were two, Hospital Without Walls and Acute Care at Home, that enabled hospital at home. We need an extension of that waiver plus a permanent program. We have a SNF at home work stream, which would allow a skilled nursing facility care in the home. So you could literally be discharged from your home to your home. Then we have a more catchall bill that is really truly the bill that would move health into the home that has all of these pieces, including primary care at home. And again, like diagnostics and labs and all the things that you would need.

Eric Assaraf:

What are the regulatory barriers to at home services? You mentioned the bill, is it because CMS doesn’t have statutory authority across those different benefit categories?

Krista Drobac:

Yes. And also it’s the way we pay. I mean, if you think about it, if you’re a physician, you can see a patient every 15 minutes if you make that patient come to you. If you go to a patient’s house, it takes you half an hour to get there. And so you’re losing triple your income, just driving around. The whole structure of how of our healthcare chassis is built on institution based care. So that’s, again, when we started digging into this, we ended up hiring two additional people because we realized that it’s such a thorny area that we’re trying to untangle all of these things. One thing that I will say is everybody in the group is dedicated to value based care and creating a structure where we are creating more value. But unfortunately what we’ve learned is you really have to build the fee for service chassis before you can actually create the value based care arrangements that are based on the billing structure of fee for service, which has been an incredible realization.

Krista Drobac:

We essentially have to move all the clinical and institutional care into a home setting and then build the bundle around a home based episode. So, I mean, I would say hopefully people remain interested in this issue and follow us at MovingHealthHome.org. We also have Twitter and because we’re going to be coming out with a series of pieces of legislation and fact sheets that kind of elucidate all of these issues. And we have an Avalere study coming out next month, as well we have in the field right now, a morning consult poll asking people, “Would you prefer to be in the home?” So we have a lot of activity going on in this area and hope that people will follow our work.

Charles Rhyee:

You talk about value based care here. I mean, it seems like to a certain extent that we need a wholesale change in how we reimburse for healthcare before this can really work. Because it sounds like you’re doing double the work here, because you have to build a fee for service model just to get back to the value based care model. But clearly CMS right now has a number of pilots going on under CMMI to explore different types of value based arrangements. You see all the commercial payers. Is that something where you can see commercial payers move faster? You hear the likes of United and the Anthems of the world all talk about more and more of their reimbursement is under value based care arrangements. Is that something you can tap into here in the shift to the home setting?

Krista Drobac:

It gets two different kinds of care. If you think about the employed population, they need more convenience. I mean, as a mom that had two kids with chronic ear infections, you wake up in the morning to someone’s got an ear infection and basically the next two days of your life is all staying home or going to doctors. If somebody could into my house, treat my kid, deliver me a prescription and I could work from home for those two days, so much productivity would be preserved and also like a parents’ mental health. Then of course you have young people who are traveling, who may want someone to come to their home before they leave or something.

Krista Drobac:

Like, there’s so many convenience options that employed population might need because there aren’t as many complex healthcare problems in the employed population. Whereas in a Medicare population, you have very complex, frail elderly people. And so if we’re going to create models whereby people can receive services in the home, it really needs to fit both markets. Even though large employers might not be serving seniors, they should still care what’s going on in the Medicare market because those rules definitely influence everything that goes on in the market. I mean the Medicare conditions of participation is a great example to become a hospital. The Medicare conditions of participation is a pretty high bar.

Charles Rhyee:

Got it. I guess just to round out here and really Krista, it’s been great to have you with us today, just remind us then again, how we can keep following you with both organizations. Just remind us again where we can find more information, how to follow you.

Krista Drobac:

The Alliance for Connected Care is ConnectWithCare.org. We have semi-monthly newsletter that goes out, it’s free. You can sign up for it. We are ConnectWithCare on Twitter. Moving Health Home is also on Twitter as MovingHealthHome, and then MovingHealthHome.org is our website. And again, we have a newsletter that includes all kinds of news. I mean, it’s news and then also analysis of things that have happened. For example, in the reconciliation package, there’s a big win for in-home care called Independence at Home. They’re making that program permanent so we’re hoping that that really does start to change the market around home based care. Those kinds of things would be in our newsletter.

Charles Rhyee:

That’s great. Well I think this is all the time we have. Krista, really, really glad to have you join us today. It was really informative and really appreciate all your insights here. And we look forward to following all the work that you’re doing with both organizations.

Krista Drobac:

Thank you. Thanks so much for having me.

Announcer:

Thanks for joining us. Stay tuned for the next episode of Cowen Insights.

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