ONC creates best practices for consumer-centered telehealth without consumer companies' input

By Jonah Comstock
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JONAH_COMSTOCK_HEADSHOTThe HHS Office of the National Coordinator for Health IT (ONC) recently released a whitepaper, based on a workshop held last April, on designing telehealth and remote visits for consumers. The 20-page document is interesting, extensive, and hits on some good points about how to make telehealth convenient and effective for consumers. Yet both the whitepaper and the workshop excluded the viewpoint of established telemedicine market leaders like Teladoc and American Well, an omission that calls into question the ONC's real priorities when it comes to telemedicine.

(UPDATE: One of the authors of the whitepaper emailed MobiHealthNews to clarify that session organizers had invited "all of the consumer telehealth companies and their CEOs" to participate but none chose to attend.)

After giving an overview of the space, the whitepaper lists various learnings from the design session, including a list of nine guidelines brainstormed by the attendees, which included a number of provider groups and a few provider-focused vendors like Qualcomm, Zipnosis, and Carena. But before it even gets into the guidelines, the whitepaper highlights the concern of data cohesion versus fragmentation -- that is, making sure the records of telemedicine visits are integrated with the patient's electronic health record at their primary care provider.

"Concern over data cohesion emerged as a key discussion point in the design session," Dr. Kyra Bobinet, CEO of behavior design firm engagedIN and her colleague John Petito, write in the white paper, which they prepared on behalf of ONC. "Telehealth solutions vary widely in the degree to which they integrate back into the traditional delivery system, connect the Primary Care Physician (PCP)-patient relationship and load to the main health record. As a result, tradeoffs between consumer convenience and data cohesion have arisen as a potential issue for patient safety and continuity of care."

The paper then lists four layers of care, starting with (1) in-person care, moving out to (2) e-visits with the patient's primary care physician, (3) e-visits with specialists and nurses connected to the PCP, and finally, layer four -- the Teladocs, American Wells, and MDLives of the world.

"The farthest out, layer 4, of the model, and furthest from the center of integrated care, would lay telehealth that functions completely separately from the existing care team and their network," they write. "This would include encounters that are one-off, stand-alone, like some employer-sponsored eVisits, community-based retail clinics and kiosks, as well as solely consumer apps and devices. Telehealth technologies in this layer run the risk of diffusing patient data and disrupting continuity of care without an integrated data. Risks to the consumer in this layer may include repeated tests, incomplete diagnoses (due to partial data), inappropriate use of telehealth where in-person exam is indicated, medication interactions, and low patient adherence."

The ideas in the whitepaper about designing telehealth for consumers are worthwhile. They include taking behavioral lessons from social media to create positive feedback loops, making consumers the "quarterbacks" of their own data, and using Uber-like technologies to create seamless integrations between online and in-person care. But the exclusion of the telemedicine companies that are raising $50 million rounds and going public, the companies that are essentially putting telemedicine on the map right now, is problematic. Because if the ONC is really interested in making telehealth appealing and easy to use for consumers, it should be listening to the companies that have accomplished and are accomplishing just that.

Which isn't to say that fractured care is a non-problem. But it's a problem that will best be solved by working with telehealth vendors, not a problem to be pinned on them at meetings they don't attend. In fact, providers are already the fastest-growing customers for American Well, and both American Well and Teladoc told MobiHealthNews in a recent interview that they're adapting to better serve those customers -- which surely includes learning how to integrate their systems with EHRs.

Telemedicine is becoming more and more important to the future of healthcare. So it's good to see the ONC focused on helping providers creating best possible telemedicine experience for patients. But if their goal is really to find the best practices for consumer-centered telehealth, they can't ignore the services that consumers already use.

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