Recently, the U.S. Department of Health and Human Services requested information from the private sector on innovative approaches to chronic disease management, especially in underserved populations. We submitted the full comment below in response.
Dear ADM Giroir and Dr. States:
In response to your request for information about innovative solutions to chronic disease management using novel technologies, we write to offer our perspective from Lark Health, a leading provider of virtual chronic disease prevention and management solutions.
Lark provides patients with health coaching to prevent or manage their prediabetes, type 2 diabetes, hypertension, as well as their overall health. Lark provides text-based counseling that is personalized to every user, based on their specific health needs. Lark’s virtual care platform connects with several bluetooth-enabled health monitoring devices, such as at-home blood pressure monitors, glucometers, activity trackers, and body weight scales to provide text-based counseling based on the device readings or measurements and seamlessly integrates with provider and payer workflows for care coordination and escalating patients who require intervention or specialized care from their care team. Lark leverages conversational artificial intelligence (A.I.) technology to maximize user engagement and provides hyper-personalized coaching through text-message interactions, gentle “nudges” or reminders and positive reinforcement. Lark can ensure a patient connects with their physician when it’s important and triages patients requiring greater level of care to the patient’s care team. Lark’s counseling is available to the user 24X7.
Payers and providers are increasingly looking to improve outcomes and reduce costs for their members and patients. According to the Centers for Disease Control and Prevention, six in 10 adults in the U.S. have a chronic condition, while four in 10 adults in the U.S. have two or more. Chronic conditions continue to be the leading causes of death and disability, as well as leading drivers of the nation’s $3.5 trillion in annual health care costs. Older adults in underserved populations can benefit the most from a virtual care platform such as Lark. Our platform combines conversational A.I. with connected devices to encourage ongoing behavior change and healthy habits. Lark’s ability to integrate with providers and payers provides the inter-connectedness which truly benefits the patient and their health outcomes. Our A.I continuously learns how to personalize the experience for the patient with each interaction and supports their variable needs and other social and economic factors that might affect their health.
Being a virtual care platform, Lark is infinitely scalable and can reach millions of patients instantly. Lark also has the ability to triage patients requiring greater levels of care and intervention to the right patient care teams. Lark’s target patient population has significant overlap with the population most at risk of severe COVID-19 complications. To keep this population safe, it’s vital to reduce in-person visits that increase exposure, while continuing to provide the care these patients need. Lark understands that, now more than ever, innovative activities across the spectrum of care in underserved settings for older adults is critically important.
We encourage the Office of the Assistant Secretary for Health (OASH) to consider how virtual care platforms that leverage A.I. could be utilized, potentially through formal CPT coding and utilization, or other policies. Programs like the Quality Payment Program (QPP) and specifically, the Improvement Activity category of QPP, could be modified to include activities where A.I. or Machine Learning (ML) would be recognized for “High Weight” credit. Even a small step such as this would begin to dovetail digital A.I. and ML technology into value-based care initiatives and the weight designation would help justify the benefit to a physician and/or a practice. This recommendation has also been formally submitted in the past comment periods.
Due to COVID-19, people with chronic conditions are often forced to defer or even forego their regular care regimen, either for their own safety or because their provider doesn’t have the resources or incentives to augment their daily practices or patients’ health care regime to include digital technology like ours. In remote areas, or rather health-provider shortage areas (HPSA), pharmacy and payers could refer patients for virtual care solutions or A.I.enabled services that can continue to maintain the interconnectedness with the patient’s ecosystem. In fact, in a study published this year, our clinical research team found that out of the 25,000 patients enrolled in our virtual Diabetes Prevention Program (which has Full Recognition from the CDC), 50.5 percent live in a designated HPSA; a designated HPSA refers to a population-to-provider ratio of 3,500 to one. This compares to 23.6 percent of the general population that lives in one of these areas, showing our ability to reach even more hard-to-reach populations.
Providing patients access to a solution such as the Lark program, has the ability to escalate emergent situations to health plans’ nurse networks when needed and would empower patients to be at the helm of their own health. Being a virtual care program, our program meets patients where they are and is able to provide personalized care for those who are less able to attend in-person sessions. Lark is capable of delivering care and improving health outcomes virtually and in our HPSA research, we found that the average weight loss for users was 10.4 pounds or 4.3 percent of body weight in one year.
Virtual care solutions that leverage A.I. can deliver value by automating redundant human tasks, identifying trends in historical data and supporting optimization of clinical resources through effective triaging of patients who require greater levels of care. In order to facilitate this value to health teams and other stakeholders, such as payers, interoperability is required. The ability to pull information back into existing EMR systems and workflows to inform health team stakeholders is costly in terms of both time and money, and often challenged by many EMR vendors. Lark is able to integrate seamlessly into the EMR/ EHR workflows to help triage and provide the patient’s care team with the patient physiological data and information they need to intervene.
We encourage the Department of Health and Human Services to support the use of A.I. in such a way that it expands on physicians resources, time, and clinical decision support congruent with service codes and reimbursement. As a validated virtual care solution with an NPI as a Health Educator, CDC Full Recognition, and proven outcomes, the Lark solution could function as “auxiliary personnel,” but as the rule details, it does not fall under the referring or prescribing physician’s “supervision.” Further, a policy allowing for A.I. or ML work functions that support and/or replicate the time, interaction, and/or review of data would allow digital technology to lay the groundwork for supporting redundant or simple clinical tasks and improve patient quality while driving value by increasing revenue and reducing costs.
The new and existing details of the billing codes and the work involved is redundant in many cases and not conducive to physician workflow. For example, the policy allows a physician to bill for 16 days (or more) of remote patient monitoring for a diabetic patient who meets certain diagnosis and care plan criteria. This requires review of all patient data, and at least 20 minutes (or more) of real time synchronous communication between the physician and their patient. The policy modified who could support this process, allowing for auxiliary personnel, such as a nurse (who is supervised by a physician) to perform this task.
However, the policy does not allow within its provisions for virtual care solutions that leverage A.I. to serve the detailed functions in any capacity (e.g. patients may use glucose monitoring, health education, and coaching through Lark throughout most of the month.) Lark has dozens of glucose readings and even more electronic interactions for medication reminders, dietary nudges or reinforcements, and other education exchanges that accomplish the same things their auxiliary personnel would conduct. Yet, none of this A.I. utilization reduces the administrative, operational, or clinician burden within a physician office under the current policy.
Further, health care teams should be introduced to virtual care solutions that leverage A.I. in context. As healthcare moves toward adopting virtual care solutions, more and more data will be generated. Clinicians are currently overloaded and have a hard time digesting the data currently available to them. Virtual care solutions that leverage A.I can read that data for clinicians or patients and identify trends and meaningful patterns which will support efficiency of the clinical resources and protect the clinician’s time, that can be used towards supporting care for patients of higher acuity.
We look forward to sharing the demonstration of the Lark experience with health care teams who may be interested, so they can experience the solution and the various elements of our technology. Getting set up on the Lark coaching platform is extremely easy and our team would be eager to share the demonstration of the virtual care solution with any key stakeholder or care provider who may be interested to explore the Lark experience. The Lark solution can be experienced as an end user and the interaction with the Lark platform allows any user to experience the personalized interaction that can span days. In Lark’s experience, once a customer (be it a health care provider or health payer) has hands-on experience with Lark, this allows one to see the benefits for themselves.
Lark believes that focus on chronic conditions including: diabetes, pre-diabetes, hypertension, and/or obesity should have priority. These conditions in aging populations within rural areas allow for large impact studies to address quality and influence of A.I.driven solutions, while also assessing things like cost reduction simultaneously. The patient’s home remains the best setting for the regular management of chronic diseases, especially for aging populations, low-income individuals, and those living in rural areas. Together with improved remote monitoring capabilities and expanded access to timely and targeted virtual care, Lark is deeply passionate about providing 24X7 compassionate virtual care to patients with these chronic conditions and bringing better outcomes to more people.