Patient-Generated Health Data

Making the most of technology trends.

By Ann Burkhardt, RHIT

The controversial 1964 book, Understanding Media: the Extensions of Man, was based on ideas formulated by Marshall McLuhan, an English professor at the University of Toronto, who made the case for a strong correlation between the pattern of a culture and its primary means of communication—“the medium is the message.”¹

Today, our primary means of communication is the mobile phone. According to Guardian contributors Chris Duffey and Katie Erbs, “Every day there are more mobile phones sold than babies born. In fact, mobile is the only medium that is currently growing.”² A majority of those people have a smart phone—carrying a warehouse of personal information with them at all times. Much of this information can be used by your practice to meet your clinical and financial goals.

PROMISE

Contributing factors to this trend

• Rising importance of patient engagement in their own health care, driven by health care reform and consumer demand
• Reform of the payment system toward value-based care
• Remote monitoring of chronic conditions for older and/or more severely disabled and remotely located patients
• Wearable technology, such as wrist bands, smart watches, and video glasses for patient self-monitoring
• Video sharing—providers sharing instructional videos, and patients sharing videos of themselves doing home exercises
• Apps: Consumer wellness and clinical equipment supplementation. Findings can be geo-located, synced to the medical record, and shared with other providers
• BYOD: Bringing your own device to office visits

Opportunities this trend brings to your practice

• Personalization: Mobile technology enables providers and their clients to have a more personal, ongoing experience, and tailor the treatment plan according to the client’s or health care provider’s mobile capabilities and current goals.
• More efficient use of office time: The information the patient provides about his or her activities of daily living and/or videos of exercise performance can provide insights and alert you to unnoticed conditions that can help you adjust the treatment plan to be effective.
• Greater compliance: Adherence to a treatment plan is increased with clients who are involved in its creation and implementation.
• Coordination of care: Mobile communication between and/or among a client’s health care providers enables better continuity and coordination of care.
• Improved documentation: PGHD provides firsthand documentation of the treatment process.
• Better outcomes: The combination of increased patient involvement, more productive use of office time, better communication, and coordination of care can lead to better outcomes.

Obstacles

Licensing: Having 50 separate licensing requirements for 50 states creates barriers to the provision of electronic services across state lines. To treat clients in remote locations, you may be required to hold multiple state licenses if these clients are located in a neighboring state, even if yours is the closest medical facility.

Regulatory: The following government agencies have jurisdiction over policies concerning the use of mobile devices in the provision of health care:

• Federal Drug Administration (FDA): Responsible for regulating equipment intended for diagnosis or treatment of a medical condition. The final ruling is pending as to whether a mobile device should be considered a medical device and subject to the FDA’s regulations.
• Federal Trade Commission (FTC): Has jurisdiction over health data breaches when non-HIPAA-covered entities are involved. Regarding mobile health (mHealth), it is focused on the validity of a company’s claims of the effectiveness of their products.
• Federal Communications Commission (FCC): Regulates devices that utilize electromagnetic spectrum devices as communication devices, not medical devices. The FCC has a collaborative relationship with the FDA.

Insurance/Medicare: How are providers compensated for the processing of patient data that is collected outside of their office between visits? Evolution of our payment system toward a more value/evidence-based model, such as those being developed and used in accountable care organizations (ACO) and patient-centered medical homes (PCMH), can eliminate unnecessary procedures and improve productivity and outcomes. In the meantime, there is a notable absence of consistent policies due to state-by-state regulation of telehealth payment.

Medicare coverage of telehealth consultations began with the passage of the Balanced Budget Act of 1997 (BBA), which called for coverage in rural health profession shortage areas (HRSA) and required that a Medicare practitioner be with the patient at the time of the consultation. It specified that teleconsultant fees had to be shared between the consulting provider and referring provider. Telehealth payment was addressed in the Benefits Improvement Act of 2000 (BIPA) or H.R. 5661, amended to provide for a subsection, “Payment for Telehealth Services,” which expanded payment for telehealth services. However, it also limited payment to those eligible individuals who received services at originating sites.

Progress

• The TELEhealth for MEDicare (TEL-MED) Act of 2013 (H.R. 3077) would allow Medicare providers to treat patients electronically across state lines without having to obtain multiple state licenses.
• The Telehealth Enhancement Act of 2013 (H.R. 3306) would adjust Medicare home health payments for remote patient monitoring, expand telehealth coverage to all critical access and sole community hospitals, and cover home-based video services for hospice care and home-bound Medicare beneficiaries.
• The 21st Century Care for Military and Veterans Act (H.R. 3507) would expand access to telehealth services for veterans and their families.
• The Telehealth Modernization Act of 2013 (H.R. 3750) would update the definition of telehealth to include store-and-forward technology (information is stored in an intermediate area, where its integrity is determined before sending to its final destination) and to cover home monitoring of patients.
• The PROTECT Act of 2014 is a Senate bill that would remove Food and Drug Administration regulation from some mobile medical apps and other medical device functionality.

According to Tom Sullivan, editor of Government Health Information Technology, the FCC is providing funding under their Healthcare Connect Initiative. Their goal is to establish wider connectivity with funds for broadband services, equipment, installation, and connections to off-site administrative and data centers and research and education networks, focusing on connectivity between rural providers and urban specialists.³

The FDA has published its final guidance regarding the oversight of mobile medical apps, and it states that it would not enforce requirements under the Federal Drug and Cosmetics Act for the majority of apps as they pose minimum risk, including devices providing educational and/or motivational materials or reminders, and mobile apps that use video and games to motivate physical therapy patients to do their exercises.

Medicare has announced incremental expansion of coverage for telehealth services, but the best coverage of telehealth services is currently being provided by Medicaid in 43 states and the District of Columbia. Nineteen states now require private insurance coverage of telehealth services.

Be on the lookout for changes in legislation and the health care payment system.

You are not without influence. Take advantage of avenues to express your opinion of, support of, or opposition to pending legislation. You can also influence payment reform. Reporting of functional outcomes (FLR) and physician quality reporting system measures (PQRS) will help provide evidence of the value of telemedicine and mobile health technology, if used productively.

Your clients vary in their level of technology use and literacy, but efforts to utilize your clients’ PGHD, at any level, will reap rewards. So plug in and watch your business prosper!

Ann Burkhardt, RHIT, is a freelance writer in Grayslake, Illinois. She researches and writes content related to practice management and healthcare policy issues that affect rehabilitation. Ann may be reached at annburkhardt@comcast.net.

References

1. McLuhan, M. Understanding Media: The Extensions of Man. McGraw-Hill. 1964.

2. Duffey, Chris and Erbs, Katie, How Mobile Became Mighty in Healthcare, The Guardian, June 9, 2014. Available at: www.theguardian.com/healthcare-network/2014/jun/09/mobile-became-mighty-healthcare. Accessed June 30, 2014.

3. Sullivan, Tom, How FCC’s rural broadband funding paves path for telemedicine, Government Health IT, June 20, 2014. Website: www.govhealthit.com/news/how-fcc’s-rural-broadband-funding-paves-path-telemedicine#.U7LlxP1e54M. Accessed June 30, 2014.