Care increasingly happens between visits. Policy should support tools that help patients follow their treatment plans while keeping clinicians responsible for reviewing progress and guiding what comes next.
Formal public comment
Our comment addresses how Medicare can strengthen program integrity in remote monitoring while preserving clinically meaningful longitudinal care.
We proposed a Clinical Episode Integrity Standard: a framework for evaluating technology-enabled care based on whether it is clinically integrated, accountable, actionable, and auditable.
Evaluate the integrity of the clinical episode, not simply the technology, transaction, or employment arrangement around it.
CY 2027 Medicare Physician Fee Schedule
A framework for technology-enabled care that preserves human ownership and makes each episode reviewable from clinical intent through action.
What we recommended
Preserve appropriate clinician oversight and established patient relationships.
Avoid duplicative initiating visits when an appropriate clinical evaluation and treatment plan already exist.
Evaluate clinical integration and accountability rather than relying on employment status alone.
Strengthen safeguards against fragmented, duplicative, or low-value monitoring.
Distinguish the cost of technology from the clinical work required to interpret information and manage treatment.
Establish a clearer policy pathway for technology-enabled sensory, communication, and behavioral rehabilitation.
Why it matters
The comment uses cochlear implant care, hearing rehabilitation, tinnitus, and behavioral treatment as examples of a broader problem: many clinically important changes occur between visits, while Medicare payment remains largely organized around discrete encounters.
The submission was developed with input from clinicians and researchers across multiple disciplines.
We collaborate with clinicians, researchers, health systems, and policy leaders working to make longitudinal care more accountable, accessible, and humane.
