Powering Progress: CTeL's Vision for a Smarter Health Technology Ecosystem

The digital health revolution is here, and the Center for Telehealth and e-Health Law (CTeL) is at the forefront, championing intelligent policy for a healthier future. As a collective of leading health systems, innovative vendors, dedicated providers, and pioneering digital health innovators, CTeL is actively shaping the landscape for product development and approval. Recently, CTeL submitted critical comments to the Centers for Medicare & Medicaid Services (CMS) in response to their Request for Information on the health technology ecosystem. These recommendations underscore our commitment to fostering an environment where technology enhances care, improves outcomes, and empowers both patients and providers.

For over two decades, CTeL, a non-profit research institute, has provided evidence-based insights to inform the complex legal and regulatory world of digital health. Our mission is to serve as a vital resource for policymakers, anticipating challenges and championing solutions in telehealth, remote patient monitoring, and the ethical integration of artificial intelligence in healthcare.

Key Suggestions for a Modernized Approach

CTeL's comments to CMS outline a clear path forward, emphasizing collaboration, clarity, and sustainable innovation. Here are some of the key takeaways:

1. A New Framework for Digital Health Product Review: CTeL acknowledges CMS's traditional deference to the FDA for product approval but sees a crucial role for CMS in establishing clear criteria for clinical evidence and real-world performance data. This is particularly important for technologies that may not follow traditional FDA review pathways but still have a significant impact on care delivery and costs.

2. Modernizing Reimbursement Methodologies: To stimulate developer interest and ensure the long-term viability of digital health solutions, CTeL strongly urges CMS to modernize its practice expense (PE) methodology. A critical first step is to reclassify software and related digital service costs as direct practice expenses, rather than indirect. This change would more accurately reflect the true cost of care delivery and improve the return on investment for both practices and developers.

3. Championing Accessibility and Adoption: CTeL has called on CMS to take a leadership role in promoting patient and caregiver adoption of digital health products through enhanced data and language access. This includes:

• Addressing the Digital Divide: Recognizing that a significant portion of Americans may lack the necessary internet bandwidth for telehealth, CTeL recommends that CMS work with cellular companies to exempt digital healthcare services from data caps. Furthermore, CTeL encourages CMS to work with Congress to reinstate the Affordable Connectivity Program to help households improve their bandwidth and hardware capabilities.

• Bridging the Language Gap: With over 25 million people in the U.S. having limited English proficiency (LEP), CTeL advises CMS to invest in technical assistance for providers on using interpreters for telehealth and to promote digital health platforms with multi-language interfaces. While AI-powered translation shows promise, CTeL cautions that it is not yet a replacement for human translation and that short-term efforts should focus on proven methods.

4. Integrating AI and Technology into Value-Based Care: CTeL believes that technologies like artificial intelligence (AI) have the potential to revolutionize value-based care by improving quality, lowering costs, and enhancing population health monitoring. To avoid the pitfalls of past initiatives like the Meaningful Use program, CTeL recommends that CMS: * Prioritize flexibility and clinician involvement in technology selection. * Focus on the "Quadruple Aim": reduced costs, improved population health, enhanced patient experience, and improved healthcare workforce well-being. * Establish clear, transparent guidelines for the use of AI in areas like risk stratification and care coordination.

The CTeL Advantage: A Collective Voice for Smart Policy

CTeL's recommendations are grounded in the real-world experience of our diverse membership. By bringing together health systems, technology vendors, providers on the front lines, and digital health innovators, we ensure that our policy positions are balanced, practical, and forward-thinking. This collaborative approach allows us to develop solutions that work for the entire healthcare ecosystem.

Our pioneering research, such as the 2021 study on telehealth's role in preventing care escalations, demonstrates the value of in-depth analysis in quantifying the economic and clinical impact of digital health.

Join Us in Shaping the Future of Healthcare

The road to a fully integrated and effective digital health ecosystem requires collaboration, strategic policy, and a deep understanding of the legal and regulatory landscape. CTeL is proud to be a strategic partner to CMS and other key stakeholders in this journey.

We invite you to learn more about the Center for Telehealth and e-Health Law and how your organization can contribute to our vital work. By joining CTeL, you become part of a powerful collective voice shaping the future of healthcare for the benefit of all patients.

For more information on CTeL and our policy initiatives, please contact Lydia Homovich, Policy Analyst, at lydiah@ctel.org.