Healthcare Information Technology

OCR Publishes New Resources for MHealth App Developers and Cloud Services Providers

The Department of Health and Human Services’ Office for Civil Rights has announced it has published additional resources for mobile health app developers and has updated and renamed its Health App Developer Portal.

The portal – Resources for Mobile Health Apps Developers – provides guidance for mobile health app developers on the HIPAA Privacy, Security, and Breach Notification Rules and how they apply to mobile health apps and application programming interfaces (APIs).

The portal includes a guidance document on Health App Use Scenarios and HIPAA, which explains when mHealth applications must comply with the HIPAA Rules and if an app developer will be classed as a business associate.

“Building privacy and security protections into technology products enhances their value by providing some assurance to users that the information is secure and will be used and disclosed only as approved or expected,” explained OCR. “Such protections are sometimes required by federal and state laws, including the HIPAA Privacy, Security, and Breach Notification Rules.”

The portal provides access to the Mobile Health Apps Interactive Tool developed by the Federal Trade Commission (FTC) in conjunction with the HHS’ Office of the National Coordinator for Health IT (ONC) and the Food and Drug Administration (FDA). The Tool can be used by the developers of health-related apps to determine what federal rules are likely to apply to their apps. By answering questions about the nature of the apps, developers will discover which federal rules apply and will be directed to resources providing more detailed information about each federal regulation.

The portal also includes information on patient access rights under HIPAA, how they apply to the data collected, stored, processed, or transmitted through mobile health apps, and how the HIPAA Rules apply to application programming interfaces (APIs).

The update to the portal comes a few months after the ONC’s final rule that called for health IT developers to establish a secure, standards-based API that providers could use to support patient access to the data stored in their electronic health records. While it is important for patients to be able to have easy access to their health data to allow them to check for errors, make corrections, and share their health data for research purposes, there is concern that sending data to third-party applications, which may not be covered by HIPAA, is a privacy risk.

OCR has previously confirmed that once healthcare providers have shared a patients’ health data with a third-party app, as directed by the patient, the data will no longer be covered by HIPAA if the app developer is not a business associate of the healthcare provider. Healthcare providers will not be liable for any subsequent use or disclosure of any electronic protected health information shared with the app developer.

A FAQ is also available on the portal that explains how HIPAA applies to Health IT and a guidance document explaining how HIPAA applies to cloud computing to help cloud services providers (CSPs) understand their responsibilities under HIPAA.

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OIG Identifies Barriers to the Use of Health Information Exchanges by the Department of Veteran Affairs

The Department of Veteran Affairs (VA) Office of Inspector General (OIG) has conducted a review of VA facilities and community providers to identify any barriers that are hampering the use of health information exchanges (HIEs). OIG identified several issues that need to be addressed to improve the exchange of health information.

HIEs are used to share healthcare information for the purpose of coordinating and improving the continuity of care for veterans enrolled in a VA facility. Following a pilot program, the VA introduced the Veterans Health Information Exchange (VHIE), which uses two methods for sharing veterans’ data between VA facilities and members of VA healthcare teams: VA Exchange and VA Direct.

OIG conducted a survey and interviews at 48 lower complexity Level 2 and 3 Veterans Health Administration (VHA) facilities, along with interviews of staff in the VHIE Program Office. OIG also met with the Office of Information Technology, Office of Community Care, Office of Rural Health, Cerner, and two state HIEs.

According to the VHIE Program Office Director, all 140 VA facilities have access to both VA Exchange and VA Direct, but currently only 28 of the 140 facilities have implemented VA Direct, which connects directly to DirectTrust. The facilities that had not yet implemented VA Direct report that they had not received adequate training by DirectTrust, did not have community partners using DirectTrust, or were using alternate HIEs.

OIG suggests in its report that “Expansion of VA Direct usage to all facilities would increase the instances of health information sharing and improve the timeliness of health information exchange while efforts continue with development of community partnerships through VA Exchange.”

Based on the survey results, OIG found 46 of the 48 facilities were using VA Exchange, VA Direct, or both, and only two facilities used neither. 22 facilities reported exchanging healthcare data by scanning, faxing, or mailing patient information.

Survey respondents indicated they needed additional training on HIEs to give them a better understanding on health information exchange and expressed a need for more community partners. There were also technology challenges with viewing community health information through VA Exchange, which required them to sign in to view the electronic health record and then sign in to the Joint Legacy Viewer (JLV) in order to access patient information from community partners. There were also issues with the quality of JLV data, access was not user friendly, and the cumbersome process delayed accessing patient information.

There are currently two contracts establishing community coordination for VHIE and 56 VHIE community coordinator positions to support facilities and Veterans Integrated Service Networks. Coordinators are required to provide training, policy, and process assistance to VHA directors and staff to enhance infrastructure, outreach, and training.

OIG found there was considerable variation in engagement across the 56 VHIE community coordinator, ranging from a high level of participation to next to none. OIG also discovered that when a coordinator leaves the position, it is common for communication issues to be experienced and training to suffer, which creates a barrier for staff knowledge and ability to use the programs.

“With the addition of more training, communication, and future planned technological changes, VHA could more effectively streamline the continuity of care received by veterans,” wrote OIG. “Electronic Health Records Modernization should alleviate some of the technology challenges currently experienced with the use of VHIE.”

The Under Secretary of Health concurred with the 4 recommendations made by OIG:

  • Review the barriers related to the use of VA Direct and increase the number of facilities using VA Direct to share health information.
  • Evaluate the VA Exchange and VA Direct training and education programs and increases accessibility to VHA staff, community partners, and veterans.
  • Increase the number of community partners, including more state exchanges and other HIE stakeholders to facilitate the expansion of bidirectional health information exchange.
  • Evaluate the performance work statements of the Veterans Health Information Exchange community coordinators and confirm compliance with the scope of work.

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States Start to Make Temporary COVID-19 Telehealth Changes Permanent

Following the decision of the HHS’ Centers for Medicaid and Medicare Services (CMS) to expand access to telehealth services and increase coverage in response to the COVID-19 pandemic, states introduced temporary emergency waivers to their telehealth laws. Healthcare providers and patients have welcomed the changes to telehealth policies, which improved access to telehealth services to help control the spread of the virus, SARS-CoV-2. There have been increasing calls for the changes to be made permanent, and several states such as Massachusetts, Colorado, and Idaho have taken steps to ensure the changes continue after the COVID-19 public health emergency is declared over.

On March 16, 2020, the Massachusetts Board of Registration in Medicine (BORIM) approved a new policy that states the same standard of care applies to in-person and telehealth visits and a face-to-face encounter is not a pre-requisite for a telehealth visit. The policy was introduced on a temporary basis in response to COVID-19, but on June 26, 2020, BORIM made the policy change permanent. This is the first telehealth-specific policy to be adopted by BORIM and Massachusetts was one of the first states to make temporary COVID-19 telehealth policies permanent.

There have been increasing calls at the Federal level for the expansion of access to telehealth services to be made permanent and for there to be continued reimbursement parity for in-person and virtual visits when the COVID-19 nationwide public health emergency is declared over.

CMS Administrator Seema Verma has expressed support for the expansion of telehealth access to continue and, at a recent meeting of the Senate Committee on Health, Education, Labor & Pensions (HELP), the 30+ temporary changes to Federal telehealth policies were discussed and Congress was urged to make several of the changes permanent. There is a commonly held view that telehealth can improve patient outcomes, help providers deliver a better patient experience, and that telehealth will help to reduce the cost of healthcare provision.

Two Federal policy changes that have attracted considerable support are the relaxation of the Medicare originating site requirement to allow physicians to provide telehealth services to all patients, no matter where they are located, and expansion of the number of telehealth services covered under Medicare.

These and other policies changes have received support at the state level. Several other states have now taken steps to improve telehealth access. Colorado Governor, Jared Polis, signed a bill this week that prohibits health insurance companies from requiring a patient to have a pre-established relationship with a virtual care provider. The law, which applies to Medicaid and state-regulated health plans, also prohibits insurers from imposing additional location, certification, or licensure requirements on providers as a condition for telehealth reimbursement and the restrictions on the technology that can be used to provide telehealth services have also been removed. Audio or video communication solutions only need to be compliant with the HIPAA Security Rule.

Idaho Governor Brad Little has similarly taken steps to make the COVID-19 changes to telehealth laws permanent, including the state’s temporary telehealth rule waivers that increased the medications that could be prescribed in telehealth visits, the broadening of the technology that can be used for providing telehealth services, and the change that allows out-of-state providers to treat patients virtually.

“Our loosening of healthcare rules since March helped to increase the use of telehealth services, made licensing easier, and strengthened the capacity of our healthcare workforce – all necessary to help our citizens during the global pandemic,” said Gov. Little. “We proved we could do it without compromising safety. Now it’s time to make those healthcare advances permanent moving forward.”

All states expanded access to telehealth services for Medicaid beneficiaries following the announcement by the CMS about the expansion of access to telehealth and increased coverage. Many more states are now expected to make the emergency changes permanent.  However, health insurers must also make changes and confirm that they will continue to reimburse physicians for virtual visits at the same rate as in-person visits, otherwise it is likely that telehealth will be dropped in favor of in-person visits.

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Senate HELP Committee Considers Permanent Changes to Telehealth Policies

The Senate Health, Education, Labor, and Pensions (HELP) Committee is considering which of the 31 recent changes to telehealth policies should be kept in place when the COVID-19 national public health emergency comes to an end.

The temporary changes to policies on telehealth have served to expand access during the COVID-19 public health emergency. These changes were necessary to help prevent the spread of COVID-19 and ensure that Americans are given easy access to medical services. During the COVID-19 crisis, patients have embraced the new approach and many have taken advantage of virtual visits and are using remote monitoring tools.

The June 17, 2020 Senate HELP Committee meeting was convened to explore which of the recent changes should be made permanent or at least be extended once the COVID-19 crisis comes to an end. All members of the committee supported making at least some of the recent changes permanent, with HELP Committee Chairman Sen. Lamar Alexander (R-Tenn.) advocating two permanent changes: The elimination of limitations on originating sites and the expansion of the types of providers who can be reimbursed through Medicare and Medicaid for providing virtual visits.

Sen. Alexander explained that both changes will help providers to achieve better patient outcomes, will improve patient experiences, and will help to reduce the cost of healthcare provision. There is wide support for these two changes to be made permanent. “As dark as this pandemic has been, it creates an opportunity to learn from and act upon these three months of intensive telehealth experiences, specifically what permanent changes need to be made in federal and state policies,” said Sen. Alexander. He suggested that were it not for the pandemic, the recently introduced changes may not have occurred for a further 10 years. It is too early to tell whether the telehealth changes have had any significant effect on patient outcomes, but they have certainly helped to improve access to healthcare services.

The University of Virginia (UVA) experienced a 9,000% increase in virtual visits between February and May, according to Karen Rheuban, M.D., director of the UVA Center for Telehealth. Sen. Alexander explained that Ascension Saint Thomas had gone from providing around 50 telehealth visits a year to more than 30,000 per month between April and May. Between April and May, telehealth accounted for around 45% of all visits.

The HHS’ Office for Civil Rights announced a Notice of Enforcement discretion covering the platforms that could be used for providing telehealth services during the public health emergency. Aside from public-facing platforms, apps that would not normally be permitted under HIPAA could be used for telehealth. While the move was necessary, it is one of the changes that requires closer scrutiny moving forward to ensure the privacy and security of healthcare data is not placed at risk.

The expansion of telehealth services has not proven to be a great equalizer, as many people lack the technology to take advantage of telehealth services. “The disparities in access to technology reflect the underlying inequity that exists throughout society,” said Sen. Tina Smith (D-Minn), a view shared by Karen Rheuban, M.D., who suggested “Congress should provide support for further broadband deployment, including to the home, as appropriate, to reduce geographic and sociodemographic disparities in access to care.”

There was strong support for reimbursement for telephone visits to be continued. At Massachusetts General Hospital and Brigham and Women’s Hospital, 60% of telehealth visits took place over the telephone in the past 3 months. “Telephone visits are important to cross the digital divide. We should continue that level of reimbursement to address this underserved population,” said Joe Kvedar, president of the American Telemedicine Association.

In addition to advocating for permanent changes to originating site limitations, Kvedar recommended giving the HHS the flexibility to expand the list of practitioners and therapy services eligible for telehealth reimbursement and to continue the grant and technical assistance programs and also cover infrastructure needs.

There is a commonly held view among providers that the decision to continue offering telehealth is largely dependent on reimbursement rates for telehealth. If reimbursement is lower for virtual visits, that may prevent providers from continue offering telehealth over in-person visits. Sen. Mike Braun (R-Ind) suggested that there should not be pay parity due to the differences in overheads. Sen. Bill Cassidy (R-La.) also questioned whether reimbursement should be equal when telehealth reduces providers’ overhead costs.

While access to telehealth has been expanded for Medicare and Medicaid patients, changes also need to be made in the private sector. “It would be very difficult to conduct this care model in a world where we got some payment for some things and didn’t get paid for others,” suggested Kvedar. “As much harmonization as possible would be huge incentive for adoption and expansion,” said Rheuban.

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NAAG Urges Apple and Google to Take Further Steps to Protect Privacy of Users of COVID-19 Contact Tracing Apps

On June 16, 2020, The National Association of Attorneys General (NAAG) wrote to Google and Apple to express concern about consumer privacy related to COVID-19 contact tracing and exposure notification apps. NAAG has made recommendations to help protect the personally identifiable information and sensitive health data of the millions of consumers who will be urged to download the apps to help control COVID-19.

“Digital contact tracing may provide a valuable tool to understand the spread of COVID-19 and assist the public health response to the pandemic,” explained the state AGs in the letter. “However, such technology also poses a risk to consumers’ personally identifiable information, including sensitive health information, that could continue long after the present public health emergency ends.”

Privacy protections are essential for ensuring that users of the apps do not have sensitive data exposed or used for purposes other than helping to control the spread of COVID-19. Without privacy protections, consumers will simply not download the apps, which will decrease their effectiveness. A study conducted by the University of Oxford suggests that in order for the aims of the apps to be achieved, there needs to be uptake of around 60% of a population. If consumers feel their privacy is at risk, that figure will not be achieved.

Current perceptions about the privacy protections of COVID-19 contact tracing apps were explored in a recent survey conducted on behalf of the antivirus firm Avira on 2,005 individuals in the United States. 71% of respondents said they do not plan to use the apps when they are made available. 44% were concerned about digital privacy, 39% said the apps provided a false sense of security, 37% said they did not think the apps would work, and 35% do not trust app providers.

The survey revealed most consumers do not trust Apple and Google to protect the data collected by the apps. Only 32% of respondents said they trusted the companies to protect their sensitive data, even though both companies have taken steps to implement privacy and security controls. There is even less trust in the government. Only 14% of respondents said they would trust contact tracing apps provided directly from the government. 75% of Americans said they believe their digital privacy would be placed at risk if COVID-19 contact tracing data was stored in a way that government and authorities could access the data.

In the letter, which was signed by 39 state attorneys general, concern was raised about the proliferation of contact tracing apps in the Google Play and Apple App Store. These apps are typically free to download and use and offer in-app adverts to generate revenue. Rather than using Google and Apple’s API and Bluetooth for identifying potential exposure, the apps rely on GPS tracking.

The state AGs also expressed concern that as more public health authorities start releasing contact tracing apps that use the Google and Apple API, it is likely many more developers will start releasing apps, and those apps may not incorporate the necessary privacy and security controls to comply with states’ laws.

Google and Apple were praised for the steps they have taken so far to ensure consumer privacy is protected but have been urged to go further. NAAG has requested any contact tracing app that is labeled or marketed as related to COVID-19 must be affiliated with either a municipal, county, state, or federal public health authority, or a hospital or university in the U.S. that is working with such public health authorities.

NAAG also called for Google and Apple to guarantee that all COVID-19 contact tracing apps will be removed from Google Play and the Apple App Store if they are not affiliated with the above entities, and for Google and Apple to pledge that all COVID-19 apps will be removed from Google Play and the App Store when the COVID-19 national public health emergency ends.

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Bipartisan Bill Introduced to Protect Privacy of COVID-19 Contact Tracing and Exposure Notification Apps

A bipartisan group of Senators have introduced a bill that aims to regulate contact tracing and exposure notification apps that will be used to control the spread of COVID-19.

The Exposure Notification Privacy Act is one of three bills that aim to regulate contact tracing apps to protect the privacy of Americans. The other two bills failed to gather enough support. It is hoped a bipartisan bill will have a greater chance of being passed.

Contact tracing and exposure notification technologies are currently being explored as a way of controlling the spread of COVID-19. Google and Apple have both developed the technology to support contact tracing via mobile phones using low energy Bluetooth. When a user downloads a contact tracing app it will log encounters with other individuals who have also downloaded the app. When someone is diagnosed with COVID-19, the encounter data in the app is used to notify all individuals who may have been infected by that person.

Contact tracing and exposure notification apps have been used in other countries and have helped reduce the spread of COVID-19, but there are privacy risks associated with the apps that the new bill aims to address.

The Exposure Notification Privacy Act was introduced by Sens. Maria Cantwell (D-Washington) and Bill Cassidy (R-Louisiana) and has been co-sponsored by Amy Klobuchar (D-Minnesota). The bill aims to give Americans control over their personal data and “will place public health officials in the driving seat of exposure notification development.”

The bill requires the use of contact tracing and exposure notification apps to be voluntary and for developers of the apps to implement measures that give consumers strong controls over their personal data. The bill limits the types of data that the apps can collect and places a time limit on how long personal data can be used.

In order for the apps to achieve their purpose, they will need to be downloaded by large numbers of people. For that to happen, Americans will need to be confident that their privacy is protected and their personal data will not be misused.

“Public health needs to be in charge of any notification system so we protect people’s privacy and help them know when there is a warning that they might have been exposed to COVID-19,” said Senator Cantwell. “This bill defends privacy when someone voluntarily joins with others to stop the spread of Covid-19.”

The bill requires exposure notification systems to only allow medically authorized diagnoses to ensure that false reports are avoided. The bill requires personal data collected through the apps to only be used for the purpose of controlling the spread of COVID-19 and personal data is prohibited from being used for commercial purposes. In addition to participation being voluntary, the bill will give Americans the right to opt out and have their personal data deleted at any time.

Strong security controls must be put in place to protect personal data collected through the apps and in the event of a data breach, the bill calls for all affected individuals to be notified. There will also be strict enforcement measures to ensure consumer rights are protected. Federal and state authorities will be given the right to impose financial penalties in cases of noncompliance.

“As we continue to confront the coronavirus pandemic, Americans should not have to worry about the privacy and security of their personal health data,” said Senator Klobuchar. “While contact tracing can play a critical role in helping prevent the spread of the coronavirus, this crucial innovation cannot come at the expense of consumers’ privacy.”

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Atlantic Receives Gold Stevie Award for Best Healthcare Technology Solution

The HIPAA-compliant hosting company Atlantic.Net has won two Stevie Awards at the 18th Annual American Business Awards, the premier business award program in the United States.

The Stevie Awards are part of a global business award program that recognizes companies and individuals who have made a big impact over the past 12 months and have demonstrated outstanding performance in the workplace. The program is split into 8 geographic regions with nominations received from organizations in more than 70 countries. Each year approximately 12,000 nominations are received globally.

This year, more than 3,600 nominations were received from organizations of all types and sizes in America. Almost all industry sectors were represented, including for-profit and non-profit organizations, and public and private sector companies. The nominations were assessed by more than 230 professionals worldwide.

Atlantic.Net is a global cloud service provider that specializes in managed and non-managed Windows, Linux, and FreeBSD server hosting solutions with data centers located in New York, London, San Francisco, Toronto, Dallas, Ashburn, and Orlando. The company has a strong focus on compliance and is a leading provider of HIPAA-compliant hosting solutions to U.S. healthcare organizations.

Atlantic.Net picked up the Gold Award in the Healthcare Technology Solution category and a Silver Award in the Cloud Platform category. “Since starting our business 25 years ago, we have always aimed to provide the best, most innovative solutions for our clients,” said Marty Puranik, CEO of Atlantic.Net. “This year is a poignant time for businesses to navigate, particularly in the healthcare tech sector, so we are thrilled to receive this prestigious honor from the American Business Awards.”

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CMS Eases Quality Payment Program Reporting Requirements in Response to COVID-19

On March 22, 2020, the HHS’ Centers for Medicare and Medicaid Services (CMS) announced it is easing the burden on clinicians, healthcare providers, and facilities that are participating in the Quality Payment Program and other reporting programs due to the 2019 Novel Coronavirus (COVID-19) pandemic.

The CMS is granting exceptions and extensions to reporting requirements for the 1.2 million clinicians that are participating in the Quality Payment Program and are on the front lines fighting against the virus and COVID-19 respiratory disease.

“The Trump Administration is cutting bureaucratic red tape so the healthcare delivery system can direct its time and resources toward caring for patients,” explained CMS Administrator Seema Verma.

The CMS has recognized that quality measure data collection and reporting for services during the COVID-19 crisis may not reflect the true level of performance in areas such as cost, readmissions, and the patient experience. The move will also ease the burden on clinicians during these exceptional circumstances.

Policy exceptions and extensions are being provided for 2019 and 2020 data submission deadlines for the quality reporting programs listed below:

Provider Programs

  • Quality Payment Program – Merit-based Incentive Payment System (MIPS)
  • Medicare Shared Savings Program Accountable Care Organizations (ACOs)

Hospital Programs

  • Ambulatory Surgical Center Quality Reporting Program
  • CrownWeb National ESRD Patient Registry and Quality Measure Reporting System
  • End-Stage Renal Disease (ESRD) Quality Incentive Program
  • Hospital-Acquired Condition Reduction Program
  • Hospital Inpatient Quality Reporting Program
  • Hospital Outpatient Quality Reporting Program
  • Hospital Readmissions Reduction Program
  • Hospital Value-Based Purchasing Program
  • Inpatient Psychiatric Facility Quality Reporting Program
  • PPS-Exempt Cancer Hospital Quality Reporting Program
  • Promoting Interoperability Program for Eligible Hospitals and Critical Access Hospitals

PAC Programs

  • Home Health Quality Reporting Program
  • Hospice Quality Reporting Program
  • Inpatient Rehabilitation Facility Quality Reporting Program
  • Long Term Care Hospital Quality Reporting Program
  • Skilled Nursing Facility Quality Reporting Program
  • Skilled Nursing Facility Value-Based Purchasing Program

Further information on the new reporting deadlines, exceptions, and extensions can be found on the CMS website.

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TigerConnect Secure Communications Platform Offered to Hospitals Free of Charge During COVID-19 Pandemic

TigerConnect, the provider of the most widely used secure healthcare communications platform in the United States, has announced that U.S. health systems and hospitals can use its platform free of charge to help support COVID-19 related communications during the novel coronavirus pandemic.

TigerConnect has been tracking COVID-19 and the impact it is having on the U.S. healthcare system. Unsurprisingly given the rapid spread of the virus, use of its secure communications platform has surged. The company also reports that it is receiving an increasing number of calls from customers looking to expand licenses to make sure all staff have access to the platform to expedite internal and external communication and support isolation workflows.

The TigerConnect platform can be used to create dedicated channels for COVID-19 communications to provide support for patients and staff members. The platform ensures instant and immediate communication of preparedness plans, staff schedules, guidelines on infection control and isolation protocols, and other critical information. Users of the platform can contact any person within a healthcare system instantly, without knowing their number or extension.

“As part of the healthcare community, we harbor a sense of duty to do everything we can to keep the flow of information moving as quickly as possible,” explained TigerConnect. “This is the time to remove any barriers that might keep organizations from having every tool they need to fight COVID-19.”

Hospitals and health systems that have not yet adopted the TigerConnect platform are being offered complimentary use of the TigerConnect secure texting network for up to 6 months to support COVID-19 communications. Existing customers will be provided with complimentary expansion of TigerText Essentials licenses for up to 6 months. TigerConnect has also announced that it will be extending support hours and publishing resources and conducting webinars to help current and new users of the platform optimize communications.

As has been seen in Europe, which is now the epicenter of the COVID-19 pandemic, hospitals and health systems are stretched and struggling to cope with the number of cases. Immediate, enterprise-wide communication is critical for preventing the spread of the disease.

In Singapore, stringent measures have been implemented to prevent the spread of the novel coronavirus. As of March 14, there have been 200 cases of COVID-19 in Singapore but no COVID-19 deaths. Coordinating the response to COVID-19 and ensuring resources are correctly allocated has been a major challenge, but one that has been helped by having an efficient communications system in place. 55,000 healthcare professionals in Singapore are using the TigerConnect platform and usage has increased fivefold in the past three weeks. Being prepared and having the systems in place to deal with outbreaks of disease that support fast and efficient communication has been invaluable.

“It is clear that identifying new cases quickly and sharing that information among key stakeholders is crucial to containment and treatment,” explained TigerConnect co-founder and CEO, Brad Brooks. “Our mission is to help organizations remove the barriers that might slow down those responses as we continue to partner with the organizations on the front lines of this crisis.”

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