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Four updates on telehealth and digital

Updated: Nov 14, 2023

About how long is the shelf-life of healthcare industry situational awareness? If you took your eye off the ball of a given sector (say, telehealth/digital) for a few months (say, about eight), how much important stuff would you be in danger of missing?


Assessing the shelf-life of industry knowledge is an important skill for leaders because time is precious, and it's non-obvious how much of it must be invested in ongoing education. Here I mean leaders' own time, plus the time of others (board, exec team, sales teams, etc.) It's also an existential skill here at Union, because it's our business to help our members stay current without simply re-creating the infinite hamster wheel of day-to-day industry news.


So I enjoyed the opportunity to do little natural experiment along these lines recently, while conducting a systematic update of a few-months-old Strategy Boot Camp module. The topic was How to Speak Telehealth/Digital in 2023. I judge that the learners at the original 90-minute session, held back in February 2023, would have walked out with a good general command of what was up in telehealth/digital topical territory as of that moment in time.. But what if those learners learners then put the whole topic on ice, consuming no more telehealth/digital information for eight or so months? What significant general-landscape changes, if any, would they have missed?


After thoroughly updating the module, here are four observations about meaningful changes over the last eight months in telehealth/digital. Followed by some advice for efficiently updating one's industry contextual knowledge on an ongoing basis.


1. New clinical concepts/vocabulary are now needed for 'speaking' telehealth/digital: Nephrology (ESRD, KCC) and GLP-1

All Union strategy boot camps invest time in making sure learners can speak any given healthcare subtopic’s particular lingo. No, not every single term can fit. So the question is, what's the minimum jargon set for being credible in industry conversations and effective at interpreting important news and conversations around them?


In the February 2023 version of the telehealth module, I spent most of the “key vocabulary” real estate on investment and policy terms. As of November, all that is still in there, along with two new sets of clinical terms – first, a few related to nephrology, and second, the term “GLP-1”.

  • Why nephrology? If you’re trying to be an informed interlocutor on telehealth in late 2023, you are going to need to understand what nephrology is (kidney care), what ESRD stands for (End-Stage Renal Disease), and what KCC is (Kidney Care Choices). The reason you need to know these things to speak telehealth, is that value-based care models related to end-stage renal disease are creating a market for nephrology-related digital health services—and acting as a tailwind for related startups.


  • Why GLP-1? In the telehealth learning module, we teach that direct-to-consumer (DTC) telehealth, meaning that the patient is having a virtual visit with someone who is NOT their standard, usually-in-person provider, represents a still-small slice of the overall visit pie. This is still true; however, for the November 2023 version of the bootcamp module, I added a slide about GLP-1 agonists—and the need for the competent telehealth speaker to know this term now. The reason? Consumer demand for GLP-1 agonists, AKA Ozempic and similar drugs, is causing a bit of a boom in (telehealth-enabled) direct-to-consumer online prescribing.


2. News-making organizations have continued making news

The other area of the telehealth/digital module that needed the most updates in order to deliver on the promise of keeping everyone current was, of course, the case study section. I say 'of course' because our long experience using case studies in our materials has taught us at least two things about these learning tools:

  • Good case studies are critical: It's not just that real-world organization stories bring abstract market dynamics to life. To be conversant, learners need to be aware of key players in the industry—newsmakers, organizations that help enhance one’s understanding of the different sectors within a market and different links in the revenue chain—and so on.

  • HOWEVER, it is always very dangerous to cite a real-world case study organization without checking to see what it's doing today. Real-world organizations constantly make changes. Especially the big players. Sparkling pilots fail. Newsmaking ventures get re-made. Marquee names get eclipsed.

When I revisited eight-month-old case study organizations for the 'How to Speak Telehealth/Digital in 2023' module, I found changes needed in every case. For example, our telehealth/digital module contains an overview of Amazon’s various telehealth-related businesses—because you can't avoid talking about Amazon, and you have to be up on what they are doing now. Between February and November of 2023, a couple of key change happened in the Venn between "Amazon" and "telehealth/digital.

  • Amazon Clinic’s 24/7 direct-to-consumer, largely out-of-pocket virtual urgent care service became available in all 50 US states (formerly only a subset). That is potentially, someday, a market-share changer in markets nationally. Not to mention an impressive accomplishment, given the patchwork nature of state telehealth regulations.

  • Amazon officially, pervasively (not on a small-scale pilot basis) linked Prime members to discounted OneMedical primary care services. Since, as The Washington Post points out, brick-and-mortal OneMedical offices exist in only 19 cities in the US, this amounts to a nationwide push of (insurer-reimbursed) virtual primary care services. This is also a noteworthy change in the overall telehealth/digital landscape.





3. An interesting non-change: Investment patterns (because Rock Health’s forecast was so good)

In February, I put into the deck a forecast from our friends over at Rock Health, who specialize in digital/telehealth and track that market most closely and best. They predicted: “Whenever investment starts to pick up again, digital health’s next growth trajectory will look more like 2011-2019 than 2019-2021—a slower and more sustained path that better reflects startup risk and prioritizes companies taking measured paths to success."


In November, I checked back with Rock Health and found this prediction had been... drumroll please.... bang on target. I didn’t even pull any more recent quotes for the sake of fresher-looking slides—I kept the January prediction there because, let's give credit where credit is due to those researchers for having read the crystal ball correctly.


For what it’s worth, Union’s general take on tehealth/digital investment is that even as pace of investment growth slows, there is still lots of room for telehealth and digital health solutions to find funding (even if they have to work harder at it) and keep developing market-relevant solutions. It makes sense to us because patient adoption seems likely to continue rising and the universe of potential future applications is wide.


4. Telehealth policy: Some important changes—and far more still on the way

In theory, 2023 COULD have been a huge rulemaking year for telehealth. But because there are so many different competing priorities and interests in the world of telehealth, rulemaking in this area is incredibly difficult to do. A few important changes definitely occurred across 2023; otherwise, the big news was that many more of the key policy questions were officially kicked to the end of 2024.


Back in February we taught learners that:

  • Pre-pandemic telehealth regulation was inconsistent across states; to some degree this continues; e.g., states still differ on whether, prior to online prescribing, a patient exam must be conducted, and whether that exam can be online.

  • During the PHE, many regulations were relaxed (at the federal level, creating more consistency across states); e.g., providers could communicate with patients using non-HIPAA-compliant platforms.

  • Currently, there is massive industry activity around making some of the key temporary COVID-19 telehealth flexibilities permanent or adjusting previously enacted telehealth laws and regulations.

The major developments since then include:

  • No more Zoom/Skype for telehealth: One important flexibility expired in 2023 -- the permission for telehealth to be conducted via non-HIPAA compliant platforms. No more; now providers must use technology that complies with the security/privacy provisions of HIPAA.

  • The Consolidated Appropriations Act of 2023 extended many, but not all other PHE-era flexibilities through December 31, 2024.

  • The DEA confirmed that flexibilities on prescribing controlled medications for opioid use disorder will also be extended through 2024 (a question that was hanging in the air throughout early 2023).

  • CMS's CY 2024 Physician Fee Schedule Final Rule: Earlier this month, the physician fee schedule made a couple of changes in telehealth rules; most notably, it ended reimbursement for audio-only visits. Visits must now (again) be audio and video to be considered a replacement for an in-person visit. But, it also confirmed most of the 'kicking can down the road til end of 2024' on other elements of telehealth rulemaking.

To tie a bow on all this, I like Healthcare Finance's quote from the American Telemedicine Association's SVP of public policy, Kyle Zebley, related to the physician final rule: "With nearly all of the flexibilities established during the COVID-19 public health emergency (PHE) extended until the end of 2024, we can expect a telehealth policy 'Super Bowl' at the end of next year.'"





In sum: Comprehensive, daily industry news-reading is neither needed nor possible. But checking back every few months is strongly recommended

Here is a good general rule for avoiding gaps in your industry situational awareness. If the last time you consumed an up-to-date landscape scan on a healthcare industry topic you need to be conversant on was more than a couple months ago, it's time to take action. That means either getting an updated version of the landscape scan (if you can), or manually checking for changes.


If manual checking is your only option, rather than just wandering the internet, consider the following steps:

  • Pull a general sample of reputable-source articles and analyses published on the topic within the last few weeks; look for unfamiliar terms that prompt you to ask yourself, "Wait a minute, what are they talking about?"

  • Zero in on the newsmaking organizations in your topical area. Double-check all the key ingredients of any case study, because odds are something has changed. What is it?

  • Check back on predictions to see how they panned out.

  • If it's a heavily regulated area, specifically search for policy changes. Healthcare has so many rule-making bodies that you can't assume anything like a once-a-year cadence for legal developments; some of these policy changes significantly alter the rules of the game.

Last but not least, if your organization isn't already a Union Healthcare Insight member, consider joining. We're committed to keeping ourselves and our members conversant in major healthcare market and strategy topics. It's what we do!






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