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

Because if someone is gaining water, if they have a congestive heart failure, for example, edema is something that can be tracked by weight and it's something that

a physician will absolutely want to measure to see what the trend is in that, especially if they're on LASIKs or something, how that is coming into play.

So that's one item

from the compliance standpoint, even before you get to the coding, you want to make sure that you have those three main components, the education and setup, the FDA approved device, and then the treatment and management.

The other aspects of the OIG's report that they mentioned was that the increase in RPM dramatically.

increased between twenty nineteen and twenty twenty two.

Well, in a way that's not unusual given COVID and how a lot of

practices had to pivot to

Get people to still remain compliant so that their chronic conditions did not worsen, especially in light of people with certain chronic conditions being more susceptible for COVID.

And then another part of that was that about 43% of enrollees who

Enrolled in RPM or who were enrolled by a provider in RPM did not receive all three of those core components.

And so from an FWA stem standpoint, that just jumps out as not meeting medical necessity and not meeting the elements of the code.

And what CMS is stating.

What are your thoughts on that?

I agree a hundred and ten percent, especially when you're talking about a person's weight, right?

They can go out eat Mexican and then swell up like a tick.

And and it's yet it's every four days for someone with congestive heart failure, unless they're dealing with something acute that is dramatically impacting the weight.

And in that instance, the physician should be saying you need to weigh yourself.

every day because we really need to monitor this closely to see how you're responding to a new medication or how this particular

change is impacting your overall management of the condition.

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