Rachel V. Rose

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233 appearances 1 recordings 1 series first heard Jul 2026 last heard 24 Jul

Rachel V. Rose’s voice in public audio — every appearance, attributed to the second.

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AHLA's Speaking of Health Law · Navigating the CCM and RPM Landscape · 24 Jul 2026 podcast

Provide a summary for our audience.

The way I translate that is first, you need a physician or a nurse practitioner or advanced provider to prescribe this particular service, and it must be documented in the medical record.

Along those same lines for chronic care management or CCM, there have to be two chronic conditions.

Two chronic conditions that often go hand in hand are hypertension and type two diabetes, for example, or hypertension, yeah, and cardiovascular disease, whatever the case may be.

From there

These chronic conditions have to be expected to last at least twelve months.

And so that's something that as a physician is looking at something, and the reason I'm raising that.

And Pam, your insight would be great here from the coding aspect.

A woman, for example, may acquire gestational diabetes and may have preeclampsia.

Are those two conditions necessarily going to be lasting twelve years?

So in September of twenty twenty four, HHS OIG released a report.

And what was fascinating about this report is that it was entitled Additional Oversight of Remote Patient Monitoring in Medicare is Needed.

And Pam, you and I both know as soon as one of those types of white papers or a special alert comes out, everyone in the healthcare sector's radars and rightly so go up because

What OIG is saying is hey, this is an identified area of fraud that we are going to be focused on.

So absolutely on the first page of that document in relation to RPM, they expressly state that one of the

areas that they are looking at even today is where the three main components met.

And the three main components of RPM are education and setup.

device supply and treatment and management.

And what you articulated earlier that it had to be an FDA approved device, whether that's a

glucometer, whether it's a continuous glucose monitor, whether it's a blood pressure cuff, or whether it's even someone's weight.

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