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mPulse Mobile Acquires The Big Know

The acquisition combines mPulse’s proven ability to reach and engage vital member populations with The Big Know’s learning expertise and rich media health education experiences, enabling health innovators to deliver personalized conversational experiences in preferred member channels and streaming content formats. Click to read the full release.

Hear from mPulse CEO, Chris Nicholson, and The Big Know President, Allison Gage

A Tale of Two Companies

mPulse Mobile

One thing we’ve learned from over a decade of experience and more than 400 million conversations annually is the power of education in self-efficacy and how that leads to activation. Our solutions excel at reaching and engaging diverse member and patient populations on their healthcare journey, helping customers to measurably improve outcomes. We are on a path to power over half a billion digital interactions in 2021, through a combination of engagement channels, behavioral science strategies, analytic insights, and industry expertise. Combining our engagement expertise with streaming health education creates a holistic member and patient engagement experience for our customers.

Chris Nicholson, CEO, mPulse Mobile

The Big Know

The Big Know creates health education for the streaming age. Through video courses and podcasts taught by inspiring health experts, the company drives health literacy and member engagement through powerful learning technology. Launched in 2015, The Big Know is recognized as an industry-leading learning experience platform and health education provider.

Allison Gage, President, The Big Know

Looking Forward

As consumer expectations and preferences continue to change, healthcare organizations must adjust to meet their needs and maintain strong relationships with their consumers. Quality member and patient engagement is a vital and unavoidable part of the healthcare journey. The acquisition of The Big Know empowers mPulse to meet consumer expectations with streaming health content, including podcasts and video courses. Additionally, this acquisition increases our ability to create new content and engagement experiences as consumer and organization needs evolve. We aim to always be up to date with consumer interest and behavior so our customers can provide best-in-class experiences to their members and patients. We are now able to do that better than ever.

Full Release

mPulse Mobile Acquires The Big Know To Add Streaming Health Education Experience

Pivotal industry partnership reimagines health engagement and sets forth path to drive greater health outcomes

LOS ANGELES, January 19, 2021 – mPulse Mobile, the leader in conversational AI solutions for the healthcare industry, today announced its acquisition of The Big Know, a prominent digital learning company transforming how healthcare educates consumers. The partnership combines mPulse’s proven ability to reach and engage vital member populations with The Big Know’s learning expertise and rich media health education experiences, enabling health innovators to deliver personalized conversational experiences in preferred member channels and streaming content formats.

“One thing we’ve learned from years of healthcare engagement is the power of education in self-efficacy and ultimately health activation,” said Chris Nicholson, CEO and Co-Founder of mPulse Mobile. “Healthcare organizations need to provide meaningful and relevant education to their consumers in a way that is both familiar and impactful. We realize that streaming health education experiences are the best way to meet that need.”

mPulse Mobile solutions excel at reaching and engaging diverse member and patient populations on their healthcare journey, helping customers to measurably improve outcomes. They are actively engaging nearly 50 million Americans and are on a path to power over half a billion digital interactions in 2021, through a combination of engagement channels, behavioral science strategies, analytic insights, and industry expertise.

The Big Know adds a superior ability to captivate, educate and activate individuals through award-winning cinematic content that is proven to sustain deeper relationships. The company’s unique approach to personalization allows for delivery of content when and where members need it most and supports their learning journey.

Both companies combine to set a new standard for health engagement and experience. The result is a holistic approach to digital health engagement with integrated conversational AI and rich content streaming, a major development for the industry that helps address gaps in how healthcare organizations educate and activate their members.

“We have a mission to improve health equity and health outcomes for the populations that we serve. Building on a foundation of knowledge through demographically appropriate learning strategies will help our clients and us achieve these goals and reduce health disparities,” Nicholson continued. “Our combination with The Big Know is a perfect synergy. Our legacy of engaging with hard-to-reach patient populations combines with their dedication to health literacy and formative learning experiences to ensure more educational engagements and greater outcomes.”

A deeper entrenchment in the streaming age and shifting consumer expectations demand a shift in the healthcare industry’s approach to care delivery and experiences. Quality patient engagement must be acknowledged as a vital and unavoidable part of the healthcare journey. Through this acquisition, mPulse and The Big Know will not only address these emerging industry demands but will pave the way by reimagining what patient engagement and experience should accomplish.

“When we think about healthcare delivery, member and patient engagement must include education,” said Allison Gage, current President of The Big Know, and mPulse’s new Chief Engagement Officer. “We must help consumers better understand and learn the skills to activate their personal health journey and give them the confidence and motivation to seek the best possible care. Only then will they take the necessary action to be healthier and happier. Our collaboration with mPulse allows us to accomplish this and so much more, and our investors, such as LFE Capital are excited about this new direction for The Big Know.  This is a most meaningful year in healthcare and a time for transformational health engagement.”

mPulse Mobile Celebrates Health Equity with Third Annual Activate Awards

UPMC, Priority Partners, Premera Blue Cross, Inland Empire Health Plan and others receive awards recognizing their innovation and results in improving health consumer activation and health equity.

mPulse Mobile announces winners of the Activate Awards each fall during its annual Activate conference. The Activate Awards recognize customers and partners that have driven impressive results like most significant outcome, best use of Conversational AI and achieving health equity.

Winners of the Activate Awards are on the forefront of healthcare consumer engagement, leveraging Conversational AI and omnichannel engagement solutions to build meaningful relationships with their consumers and activate them in their health. Award submissions were evaluated on both qualitative and quantitative results.

2020 Activate Award winners include:

UPMC – Most Significant Outcome (tie)

A world-renowned health care provider and insurer, Pittsburgh-based UPMC is inventing new models of accountable, cost-effective, patient-centered care. It provides more than $900 million a year in benefits to its communities, including more care to the region’s most vulnerable citizens than any other health care institution. UPMC Health Plan, the largest medical and behavioral health service insurer in western Pennsylvania, offers health insurance to all Pennsylvanians regardless of their life situation, including employer-sponsored plans, Medicare, Medicaid, Children’s Health Insurance (CHIP) and plans offered through the Affordable Care Act.

mPulse’s solution supported a 10-week Home Run for Health program to over 2,400 Health Plan members who signed up through their employer group plans. After kickoff messaging, members received weekly check-ins and surveys with an end-of-program survey after completion of touchpoints, all via interactive text message. Outreach connected members to curated content around healthy eating, exercise tips, and other weight-loss topics.

Member engagement rates were very high, with over 72% of members engaged during the program. Program retention was strong, with only a 1.5% opt-out rate in spite of the challenge faced with the growing concern surrounding COVID-19 and the nationwide shutdowns.

Priority Partners – Most Significant Outcome (tie)

Priority Partners is a Medicaid Managed Care Organization that serves individuals throughout the State of Maryland.

Priority Partners sends out notices to Medicaid members to remind them it is time for them to complete their renewal (Redetermination) with the State of Maryland. In previous years, notices have been sent by mail and email, but this audience is often transient and hard to reach.

The mPulse Mobile solution engages members about renewal through mobile channels and was able to reach an average of 78.9% of members who were due for redetermination. Combined with the other traditional methods of communication, an average of 75.9% of members renewed their eligibility each month and kept their membership with Priority Partners, a significant improvement that helped more members maintain continuity of coverage.

Premera Blue Cross: Most Innovative Solution

Premera Blue Cross is a leading health plan in the Pacific Northwest, providing comprehensive health benefits and tailored services to about 2 million people, from individuals to Fortune 100 companies.

Premera’s main goal is to make healthcare easier to use. Premera’s messaging mission is to provide members with information about their healthcare and benefits quickly, educate them about Premera tools to navigate their health, empower them with actionable messages that lead them to self-service tools that lead them to solutions, and ultimately change their members’ behavior so they get the most out of their health plan while decreasing the need to call customer service.

The mPulse Mobile Engagement Console provides an avenue for 2-way communication between Premera and members via text. The Engagement Console became the communication channel that allows customer service representatives to text back and forth with members from these plans to assist them with booking appointments with high quality providers as well as answer questions within privacy and legal constraints.

The Engagement Console was also used to send confirmations via text when a member uses the Premera mobile app or the Premera Pulse website to schedule an appointment.

Since deploying the program to 5 top plans, a significant portion of members have scheduled appointments with top providers and have an average of 1.5 appointments per member who engages with the Premera team via the program.

Inland Empire Health Plan: Achieving Health Equity

Inland Empire Health Plan (IEHP) is a not-for-profit Medi-Cal and Medicare health plan located in Rancho Cucamonga, California. With a network of over 4,000 providers and more than 2,000 employees, IEHP serves more than 1.3 million residents in Riverside and San Bernardino counties who are enrolled in Medi-Cal, Cal MediConnect Plan (Medicare), or the Healthy Kids Program.

IEHP launched an important solution with mPulse Mobile aimed at addressing social isolation over 6-7 weeks with 92,000 Medicare and Disabled members of IEHP. The Conversational AI solution was used to identify self-reported social isolation levels and challenges of staying at home during the COVID-19 pandemic.

The solution consisted of 15-30 automated conversations that offered support and provided tips and resources to combat social isolation and “stay at home” challenges. These included the use of Fotonovelas to communicate a visual story on the challenges of staying at home. Members received an average of 20 tailored, conversational touchpoints. Program satisfaction was very high; over 86% of members found it helpful, with higher satisfaction in Spanish-speaking segments than English speakers.

Midwest Medicaid Managed Care Plan – Best Use of Conversational AI

This Medicaid Managed Care Plan worked with mPulse to increase and improve the number of well-child, dental, and lead screening visits required to achieve quality, state, and plan operational goals. Since a large number of members are under 18, these EPSDT and HEDIS gaps are very important in managing the preventive care and overall health of the population.

Using mPulse’s conversational AI solution, members were targeted to remind them to complete their visit with a series of automated touchpoints. Outreach was orchestrated to match the best reminder content to each individual member. In total, approximately 100K gaps were targeted by the mPulse solution, successfully driving over 65,000 provider visits and making significant improvements in screening and visit completion rates.

Southeast Medicaid Managed Care Plan – Most Improved Customer Experience

This Medicaid Managed Care Plan leveraged a mobile outreach strategy that included implementing 2-way, automated text messaging solutions to improve overall health engagement as well as improve a hard-to-reach population’s completion rates of Health Risk Surveys. They use mPulse’s platform to reach these members using a new channel (SMS + Secure Survey). The new solution uses high-reach channels and optimized content, resulting in significant improvements to completion and member satisfaction. With ongoing optimization of content and conversational flow, completion rates have more than doubled and initial member engagement rates have improved by 75%.

“On the other side of these solutions are meaningful outcomes that are really impacting people and their health,” said Chris Nicholson, Co-Founder and CEO of mPulse Mobile. “Seeing so many wonderful partners leveraging our solutions like Conversational AI, the Engagement Console, and Fotonovelas to engage their members in meaningful ways to build valuable relationships that in turn lead to positive outcomes motivates our team every day. The Activate Awards are such an important reminder every year why we do what we do.”

Release: mPulse Mobile Adds Brendan Miller as Chief Commercial Officer and Reva Sheehan as Government Programs Strategic Market Executive

New strategic roles to drive growth and deepen relationships with government health plans.

mPulse Mobile, the leader in Conversational AI for healthcare, today announced Brendan Miller as Chief Commercial Officer and Reva Sheehan as Government Programs Strategic Market Executive.

Miller’s leadership position in the rapidly growing organization includes teams responsible for sales, partnerships, sales enablement, and marketing, driving toward meeting strategic business initiatives and proactively addressing health plan, health system, business partner, and government needs. With more than two decades of experience transforming healthcare delivery and scaling start-up to mature healthcare companies, most recently on the executive leadership team at Amwell, Miller is tasked with executing mPulse’s growth strategy and evolving go-to-market channels.

“Our long-term relationships with enterprise customers and pushing ourselves to innovate to meet the needs of incoming customers has been key to our growth, and we are eager to build on those relationships,” said mPulse Chief Executive Officer, Chris Nicholson. “Digital health is transforming care delivery, which is the future of healthcare. We continue to invest in solutions that focus on engaging every healthcare consumer as part of this new system of healthcare, with a special focus on health equity and engaging historically underserved populations. In this new era, we’re confident Brendan’s proven record of leading companies to growth and his deep healthcare experience will be a major asset to our organization.”

In addition to Amwell, Miller served in leadership roles for MultiPlan, HealthMine, Wellness Corporate Solutions-LabCorp, and America’s Health Insurance Plans.

Sheehan is an experienced government programs subject matter expert with more than 15 years of industry experience ranging from long-term care and compound pharmacy management to health plan quality and operations, most recently leading Medicare 5-Star Quality initiatives at Priority Health. She is tasked with enhancing mPulse’s support of government plans through technology, relationships, and subject matter expertise.

“We have been so excited about our partnerships with Medicare and Medicaid plans throughout the country, as well as the important impact we have helped make on those key populations,” said Nicholson. “Reva’s experience, expertise in government plans, and passion for member experience is a perfect fit for our organization and will help us continue to build solutions for this segment.”

mPulse Mobile Announces Closing of Series C Funding of more than $16 Million, Led by Optum Ventures

New investment will support mPulse Mobile’s engagement and outcomes strategy through Conversational Artificial Intelligence

mPulse Mobile, a leader in Conversational Artificial Intelligence (AI) solutions for the healthcare industry, today announced more than $16 million in funding. The round was led by Optum Ventures and includes existing investors HLM Venture Partners, OCA Ventures, SJF Ventures, Echo Health Ventures and Rincon Ventures.

Powering more than 300 million personalized, automated consumer healthcare conversations annually, mPulse Mobile’s solutions help consumers and healthcare organizations achieve better health outcomes by increasing engagement and improving communication through meaningful, tailored conversations. mPulse combines behavioral science, artificial intelligence and an enterprise-grade platform to assist healthcare organizations guide consumers to adopt healthy behaviors.

mPulse Mobile has more than a decade of healthcare consumer engagement experience, serving more than 100 healthcare organizations. The Series C investment will help mPulse Mobile further enhance solutions that deliver positive consumer experiences on behalf of its customers.

“We are excited to have the support of Optum Ventures and all of our current investors as we execute on our strategic roadmap to improve health outcomes for consumers and our customers through improved communications,” said Chris Nicholson, CEO of mPulse Mobile.

“This new investment recognizes that scale and solution performance are key factors in successfully engaging consumers in their healthcare, and we will use it to expand our consumer conversational AI capabilities, enhance our client engagement analytics platform and expand our engagement solutions across healthcare verticals.”

“mPulse Mobile enables valuable connections between healthcare organizations and consumers, while addressing a significant market need for better experiences,” said Laura Veroneau, Partner, Optum Ventures. “We believe mPulse’s innovative approach to consumer engagement can play a key role in improving health outcomes and lowering the total cost of care.”


About Optum Ventures

Optum Ventures is the independent venture fund of Optum, a leading information and technology-enabled health services business dedicated to helping make the health system work better for everyone, and part of the UnitedHealth Group. Optum Ventures invests in digital health companies that use data and insights to help improve consumers’ access to health care services and how care is delivered and paid for, and that make the health care system more reliable and easier to navigate. For more information, please visit

About HLM Venture Partners

HLM Venture Partners is a leading venture capital firm and one of the nation’s oldest and most experienced in the tech-enabled healthcare services, healthcare information technology, and medical device and diagnostics sectors. Seeking dynamic, emerging-growth companies, HLM invests in the industry’s most innovative companies, including Phreesia, Teladoc, AbleTo, Regroup Therapy, Nordic Consulting, meQuilibrium and ClearDATA.

About OCA Ventures

OCA Ventures is an early stage (Seed, Series A, and Series B) venture capital firm focused on equity investments in companies with dramatic growth potential, primarily in technology and highly-scalable services businesses. OCA invests in many industries, with a preference for technology, financial services, cyber security and healthcare technology. Founded in 1999, the firm is investing out of its fourth fund in companies spread throughout the United States. Learn more at

About SJF Ventures

SJF Ventures invests in high-growth companies creating a healthier, smarter and cleaner future. Its mission is to catalyze the development of highly successful businesses driving lasting, positive changes. We are experienced venture capital investors who have been at the forefront of impact investing since 1999.  We are passionate about generating extraordinary results, creating positive changes, and partnering with visionaries who combine these two.  Our team has invested in over 70 companies during the last 21 years, bringing time-tested perspective and expertise to partnerships with entrepreneurs.  For more information, visit

About Echo Health Ventures

Echo Health Ventures invests to build and grow great health care companies. Echo Health Ventures seeks to drive systemic health care transformation through hands-on, purpose-driven strategic venture capital and growth equity investing. As a strategic collaboration of Cambia Health Solutions and Mosaic Health Solutions, Echo Health Ventures works closely with its parent entities to catalyze the development of its portfolio companies and accelerate their innovations to scale nationally. For more information, please visit

About Rincon Ventures

Rincon Venture Partners, as well as its successor firm Bonfire Ventures, is an LA-based seed-stage venture capital firm that invests exclusively in B2B software businesses, and typically leads or co-leads a startup’s first priced round.  We back extraordinary founders who are seeking to build world-class market leaders, and aspire to serve as those founders’ most trusted advisors. Investments made by the firm’s founders include The Trade Desk (IPO), Burstly (acquired by Apple), Edgecast (acquired by Verizon), Datapop (acquired by Criteo), MessageLabs (acquired by Symantec), Orbitera and Bitium (each acquired by Google), EmailAge (Acquired by LexisNexis), TaxJar, ChowNow, Rainforest QA, Invoca, Honk and others. For more information visit

5 Key Takeaways from Speaking at the 11th Annual Medicare Market Innovations Forum

On Thursday, July 16th, 2020 our VP of Marketing, Brendan McClure, Bill Jenson from Independent Health Care, Linda Roman, and Brenda Mamber from Cenaturi Health, spoke at the 11th Annual Medicare Market Innovation Forum. BrendanBillBrenda, and Linda explored designing unique member experience and how leveraging data can build loyalty. 

Here are our 5 Key Takeaways:



 Bill and Brendan both noted that the COVID-19 pandemic has accelerated a number of existing trends in member engagement. Telehealth access outreach, check-ins with members about their wellbeing, and conversational engagement to both inform and uncover insights all took on much greater importance. For plans where these member-centric touchpoints and engagement procedures were already in place, the trust between member and plan was greater once the crisis started. Early COVID engagement strategies from the plans already engaging conversationally have given plans a unique advantage to build even deeper connections with membersBrendan gave a real example where an automated check-in with a Medicare population prompted a response from one member who said that he had not heard from anyone in two weeks and deeply appreciated the care and concern from the plan.  



When a plan can ask the right questions and supply the proper resourcesmembers are more likely to engage and leave the conversation feeling heard. Plans often have underutilized resources and interventions due to a lack of member awareness, or because plans do not know who needs what. But simply asking members in conversational channels if they are experiencing issues like social isolation or food insecurity both create the opportunity to connect them with resources and identify members who may need follow-up. By asking the right questions, a plan can uncover barriers to action such as transportation, health literacy, language, and the like. Asking and then providing the member with the appropriate resources will not only drive engagement and drive behavioral change, it will help build the trust needed to engage in future conversations. 



Loyalty is a product of building trust. A member is more likely to engage in future conversations when they feel like the plan is invested in their health as much as they are. Brendan noted that trust comes from a plan who communicates accurately, timely and quickly. In addition to the example of COVID-19 outreach from plans that were already having conversations with members regularlythe panel noted how important building trust over time was when it came to SDOH barriers. Members are more likely to share barriers and more likely to accept help and interventions when there’s trust in an established relationship. The stronger that relationship, the more confident a plan can be in retaining that member over time, and counting on them to engage in the future. 



 Because trust is established during ongoing conversations over an extended period of time, when a member is ready to transition into Medicare they are more likely to accept information and resources from their planThat level of trust will keep members open and willing to communicate with their plan on a regular cadencemPulse has found that members who received text outreach from their plan previously about health or services were much more likely to request information on their payer’s Medicare plan options via text. Leaning on the trust built throughout the relationship to continue to ask questions about their experiences with their healthcare and using that data from past conversations with the member to tailor age-in outreach can be a winning combination for both retention and member experience. 



Brendan reminded the audience that the data you get from engagement depends on the questions you askThere is value in all variations of member responses. Discovering whether a member is happy or unsatisfied with their plan creates the opportunity to tailor further engagementSentiment and intent analysis of member responses to automated outreach provides valuable feedback to the planAsking member directly how they feel about their plan, or measuring positive and negative responses to questions about their health or the COVID-19 pandemicgives plans insight on retention risks, hotspot geographies that may have provider network issues, or topics where members seem to be dissatisfied. Uncovering these potential blind spots and quantifying members’ expressed feelings toward their plan gives payers actionable data to impact everything from future engagement strategies to benefit design.

5 Key Takeaways from Speaking at Rise National

mPulse Mobile’s CEO, Chris Nicholson, spoke alongside Rex Wallace at RISE national on the Engaging Hard-To-Reach Members to Drive Action Around Quality and Risk speaking session. Chris and Rex explored how to define hard to reach Medicare members, the importance of trust in engagement, some proven strategies and results, and how the new weight on Star Measures will impact how plans think about these populations.

Here are our 5 key takeaways:  


Members who do not engage or act after multiple outreach attempts tend to face several factors that make building a connection more difficult. Sometimes the issue is a matter of access to the content or channel. Language or cultural barriers can severely limit engagement with English-only outreach, and members who rely solely on smartphones for internet access can be much harder to reach via email and web portals. Our research shows that lower engagement tends to correlate with higher impact from Social Determinants of Health (SDOH). That impact can take many forms, from housing insecurity which causes mail to be delivered to old addresses, to lower overall health literacy that makes one-size-fits-all reminders to close care gaps less meaningfulBut the area that Chris and Rex explored the most was the members who simply did not trust their plan 


Data from Oliver Wyman suggests that trust is vital when members consider taking action on their health. A 2017 study that Chris and Rex discussed in the session shows that consumers are just as likely to consult with friends and family on whether to seek medical care as they are to ask a provider. And they were less than half as likely to check with their health plan. The difference is the level of trust and strength of relationship. Plans have an opportunity to build trust in their outreach by making it more conversational and tailored to the member.  


 Asking members questions – Why haven’t you visited the doctor? Why didn’t you refill your prescription last month? – and listening to their responses creates a twofold impact: You build trust by letting the member guide the conversation, while also uncovering barriers to action. Members who identify barriers feel heard and can be connected to plan resources to overcome them like ridesharing, appointment scheduling assistance, or health literacy-building content. And gathering barrier data can give vital insight to your quality improvement strategy.  


Rex and Chris dove in on how to define and measure trust in a member’s relationship to the plan. They used a four-part definition of trust from the American Psychological Association to explore how plans can measure something so qualitativeFirst, trust is based on past experiences and prior interactions, so plans should take steps to treat engagement as a long-term relationship rather than a series of campaigns and monitor engagement rates over time and across touchpoints. Second, trusted partners are seen as reliable, dependable, and concerned, which makes analyzing the sentiment of member responses to outreach a possible proxy for measuring how members view their plan. Third, trusting parties disclose information to each other and take on risk by relying on the other. This is where measuring and analyzing member responses to questions that ask for them to disclose things like barriers, SDOH impact, or other challenges can help plans understand the level of trust members place in them. Finally trust means confidence and security in the caring responses of a partner – which means members lose trust in plans that ask questions but don’t seem to listen or act on answers. Chris noted that when plans ask a member if transportation is a challenge but don’t correctly understand their answer (or don’t provide a remedy if they say yes), they damage the relationship they were trying to strengthen. 


Rex noted how the major changes from CMS to emphasize Member Experience and Complaints measures in formulating overall plan Star Ratings are a game changer for MA plans’ engagement strategies. These changes make the importance of each member’s relationship with their plan all the more critical to understand and improve. Previously, outreach focused on driving specific member actions to complete screenings, refill prescriptions or control a chronic condition. CAHPS measures making up over 50% of the 2023 Star Ratings measurement weights will mean that outreach should shift to measuring member experience and coordinating interventions based on their responses. Rex reminded the audience that one of the most important factors in member satisfaction and experience is what happens during provider encounters, which has traditionally been a blind spot for most plans. Chris and Rex said targeted and two-way outreach to gain insight about those blind spots is a great first step to incorporating the new CMS rule into engagement strategies.  

Our Reaction to the Two New TCPA Rulings from the FCC

This past Thursday, June 25, 2020, was a busy day for the Federal Communications Commission (FCC) and their oversight on the Telephone Consumer Protection Act of 1991 (TCPA). 

That law, and the FCC rules enforcing it, create the primary regulatory structure that guides how automated outreach via phone and text to cell phones lawfully happens in the US. As a result, mPulse is always monitoring FCC rulings, federal court cases, and Congressional actions that relate to how our customers can ensure they are always compliant with the TCPA. So, when the Commission issued two binding Declaratory Rulings relating to the TCPA last week, we knew it was important to examine what was (and wasn’t) changing as a result. Here is our breakdown of the two new rulings. (Note: I’m not a lawyer and this should not be taken as legal advice.) 

P2P Alliance Petition 

What it isThe FCC ruled on a 2018 request from the Peer 2 Peer (P2P) Alliance asking for clarification on what constitutes an “auto-dialer” that calls or texts cell phones. This definition is key to determining if the TCPA applies to a technology platform.  

What happened: The Commission’s Consumer and Government Affairs Bureau (CGB) made two key rulings. First, they clarified that an auto-dialer must store or generate random or sequential phone numbers and call them without human intervention. They specifically clarified that a technology platform where a human had to manually enter each number prior to calling or texting would not be subject to the TCPA, no matter how fast they would be able to call or text. Second, the FCC reiterated a long-standing view that, even when using an auto-dialer subject to the TCPA, calls and texts made to cell phones with the consumer’s prior express consent are permitted. They also took a moment in the ruling to note, “The Commission has repeatedly made clear that persons who knowingly release their telephone numbers for a particular purpose have in effect given their invitation or permission to be called at the number which they have given for that purpose, absent instructions to the contrary.” They finished by saying that if P2P was an auto-dialer, but was only calling or texting consumers who had provided their cell phone numbers to the calling parties, those calls/texts would be permissible because they were made with prior express consent. 

What it means: Because of our scale and the crucial nature of the calls and texts (among other channels) our platform powers for our healthcare customers, mPulse has always operated under the assumption we fall under the TCPA, even as the definition of an auto-dialer has been debated in federal courts. So, our operations won’t change due to any update to that definition. The reiteration that providing a mobile phone number constitutes prior express consent, absent instructions to the contrary, is a good and clear reinforcement of the FCC’s view of how consumers can opt into non-marketing text and phone outreach.   

Text of ruling:  

Anthem Petition 

 What is it: The CGB also ruled on a 2015 request from Anthem that was asking for an expansion of the exemptions for healthcare messaging under the TCPA. Specifically, Anthem asked for the FCC to rule that calls and texts from Anthem (and plans or providers in general) that concern healthcare should not need to have prior express consent as long as consumers have an easy opportunity to opt out. The existence of a prior established relationship between the plan and members is enough, in their argument, to start that outreach. Second, they asked that broader healthcare calls/texts should be exempt from the TCPA entirely because they are welcomed by consumers and represent urgent healthcare concerns. Specifically, Anthem listed calls/texts on subjects like preventive medicine outreach, case management, to “educate members about available services and benefits,” and the use and maintenance of benefits.   

What happened: The Commission declined to grant Anthem’s requests. They emphasized that consent must be obtained prior to starting outreach regardless of an existing relationship, but noted that healthcare callers should have little problem obtaining that consent. The FCC also disagreed with a few of the Anthem petition’s arguments for making a content-based exception to the TCPA for non-emergency healthcare calls and texts.  

What it means: The FCC’s ruling is positive in a number of ways. This was the first time that the FCC directly addressed calls and texts that health plans typically send their members. The FCC’s treatment of Anthem as a healthcare entity – consistent with their definition of a “healthcare provider” as a HIPAA-covered entity and/or their business associates as those terms are defined under HIPAA – helps health plans get clarity that the TCPA protections for healthcare calls and texts – which require prior express consent instead of the prior express written consent that general marketing calls require – apply to their health-related messaging as well as those from hospitals or doctors’ offices. Ultimately the FCC’s move to look at health plan calls and texts and determine that no change was needed gives us confidence in the compliance procedures we have helped our plan customers follow for over a decade.

Text of ruling:

The Importance of Tailored Telehealth Engagement for Low-Income Populations

Throughout the COVID-19 pandemic, mPulse and our customers have placed a major focus on delivering programs geared toward vulnerable, hard-to-reach and culturally diverse populations. We have been encouraged by the results so far. Early analysis of 2,500,000 messages across multiple mPulse customers sent to approximately 319,000 Medicaid plan members in Cook County, Illinois (primarily the greater Chicago area), showed individuals who had greater SDOH barriers were actually more likely to engage with our COVID-19 programs than those with lower SDOH barriers. There are several factors that contributed to this reversal in normal engagement levels. Lower income populations were disproportionally infected with COVID-19 cases, which created urgency for engaging with COVID-19 content. Outreach that provided information about free resources and subsidies were most valuable to members who were more adversely impacted by SDOH. And lastly, content was tailored to culturally diverse populations. Program content was developed in multiple languages, and our customers leveraged our mobile-optimized fotonovela outreach. Every healthcare organization understands the importance of engaging hard-to-reach populations, and as we look to the ‘new normal’ post-COVID, there are important learnings from this period that should be a part of every engagement strategy.

One of the more prominent aspects of the new normal will be the accelerated and important role of telehealth in care delivery. The pandemic has forced rapid adoption by providers, plans, and patients. This is a positive step for many reasons: more cost-efficient delivery of care, and much improved access and convenience for healthcare consumers.  However, low income populations have some of the lowest levels of adoption of telehealth services, so as healthcare adapts and new innovative care deliver approaches are developed, we must ensure the hard-to-reach are included in the shift to virtual care, and apply proven strategies for engaging these populations on topics that are important to their health.

Telehealth has been sold as an equalizer for disadvantaged and rural communities, but there are challenges with this. Safety net providers have been slower to adopt telehealth in comparison to larger health systems. Rural and community health clinics lack the funding to keep abreast with the latest technology, but also manage populations who lack internet coverage and/or are at poverty levels that prevent them from accessing the technology needed to connect virtually. 2019 data suggests only 50% of low-income households have home broadband, and over 30% of these households are smartphone-reliant for internet.

The low adoption of stable home internet and desktop/laptop computers in these populations means government-subsidized mobile phone programs must include smartphones with capabilities to support virtual visits. The data needed to support these visits must be included in the phone’s data plan, so patients are forced to decide whether to use their own mobile plan data to have a health consultation or connect with their friends through social media. And the telehealth platform itself must be a high-quality experience comparable to leading healthcare providers for any chance of success.

But providing the technology is not enough. As with almost all health services and benefits, awareness and education are critical for lasting adoption. Health plans and providers must invest in telehealth engagement, so that their members and patients know the service exists, how and when to access it, and provide support so they become fluent with the technology. All these potential barriers are accentuated with lower-income and culturally-diverse populations. But those populations must be areas of significant investment in engagement and education, if there is any chance of healthy equity in the new normal.

Key Takeaways from Last Week’s Webinar on Improving Member Engagement

The Strategic Solution Network hosted mPulse Mobile and Martin’s Point Healthcare to discuss Improving Member Communication on Tuesday June 9, 2020 as part of the 11th Medicare Stars, HEDIS, Quality and Risk virtual event. Josh Edwards, Stars Program Manager at MartinPoint Healthcare, discussed best practices, while mPulse’s Solution Marketing Manager Jim Burke covered how data can change the conversation with the senior population and transform member engagementHere are our biggest learnings from the event: 

1. Meet Seniors Where They Are 

Jim talked about how 90% of seniors who have phones (which is also around 90%) text regularly, while only 22% of that same audience are looking for new apps. App adoption and use among seniors is also declining slightly, according to the AARP. Member communication is difficult, so plans should not make it harder by asking members to engage in channels that they don’t normally use. mPulse has found mobile channels, especially conversational SMS, to be the best way to reach the Medicare population at scale. These members, when compared to other groups that mPulse engages, truly embrace the channel: they tend to prefer longer multi-turn conversations, view follow-up reminders as caring rather than annoying, and use emojis at a higher rate than any other age group.  

2. Let the Data Drive  

Getting a clear view of your population through data was a major theme for both presentations. Leveraging data from outreach itself gives you the tools to drive behavioral actionable outcomes. Jim noted that when outreach is conversational, the information flows two ways: the member is connected to resources and servicesand the plan gains insights on member experience and barriers stopping members from taking key actions. Those insights can be difficult to gather without automated conversations and are some of the most actionable available to quality improvement teams. 

3. Reimagine the Communication Cycle  

Josh talked about the way rethinking the communication cycle can ease processes and improve engagement in the long term. He referenced his favorite process from what he calls the Pink Book” or Making Healthcare Communication Programs Work from the National Cancer Institute ( )  as a great tool that has helped him and his teamPutting a process in place, whether from the pink book” or elsewhere, keeps quality teams thinking strategically about member communication. 

It is equally important to make sure vendors are on the same page with any communication strategy. The last thing your organization wants to do is muddle the message you are trying to send members because your vendors have a different idea of what the message is or was in the first place. Josh emphasized the need to coordinate across partners and include them in the big picture of your communication process. 

4. SDOand Your Audience  

Both Jim and Josh emphasized the importance of putting your members in context. Who are you trying to reach and what type of barriers do they face to complete a key screening or refill a prescription? Uncovering barriers and tailoring content to fit your members’ challenges should be a core part of any quality improvement and member engagement strategy. SDOH effects all aspects of healthcare, including member communicationJim showed how mPulse is using SDOH Indexing before starting outreach to identify likely impact of SDOH factors on engagement. This helps adapt strategies to fit the population and anticipate engagement challenges earlier. 

5. Language Matters  

It may seem like a basic reminder, but many plans still struggle to meet member preferences around language. The very first question from the audience was about serving populations that need outreach in more than just English. Josh from Martin’s Point said the ability for outreach vendors to switch between languages is keyJim agreed that any automated system must be able to capture the preferred language both prior to sending out any communication and as members identify a preference during outreach. He also noted that content should be created within the native language when possible, as opposed to a direct translation from English.

How the New CMS Final Rule will Change Medicare Member Engagement

On Friday the Centers for Medicare and Medicaid Services (CMS) issued a Final Rule that included confirmation of a number of big changes to Medicare Advantage and Part D Star Ratings that were proposed back in February. These changes will have a big impact on Star Ratings engagement strategies. Among other updates codifying existing policy and contracting rules for Medicare, CMS is going forward with tweaks to the quality measurement system that can dramatically impact plan ratings and performance. CMS is estimating that these changes alone will result in a reduction in $3.65 billion in federal spending in the next decade by tightening Star Rating methodology. But beyond the immediate financial impact, the rule means plans will need to ensure they have a competitive engagement strategy around Member Experience and invest in building relationships with their members now.  

So what is changing in Star Ratings for Part C and D?

1. Patient experience and complaint measures will be quadruple-weighted.

This change means that measures from CAHPS and the rest of the category will now be the most influential part of overall and summary measure calculations. Measures like Getting Needed Care will now impact an MA-PD plan more than the Medication Adherence or Outcome measures – their triple-weighting no longer the highest among the non-Improvement measures. The jump from the current 2x weighting to 4x will mean that member responses to CAHPS questions about access and satisfaction will be major determining factors in plans’ overall ratings for the 2021 measurement year.

2. CMS is moving to reduce the impact of outliers on Star Rating cut points.

By using a process called Tukey outlier deletion, CMS will remove plans with measures that are statistically outlying from the calculations that determine rating cut points. This means that plans that are doing abnormally well or poorly on a measure will not exert extra influence upward or downward on the “curve” that determines the rating for all plans. This is where CMS projects to reduce spending. The most likely effect of outlier deletion will be to remove lower-performing plans and increase cut points – which will likely reduce the number of plans receiving higher overall ratings and the bonus payments that come with them. CMS is delaying implementation until the 2022 measurement year due to the COVID-19 outbreak, giving plans some additional time to assess the impact and prepare.


What does this mean for Medicare member engagement?  

mPulse Mobile partners with Medicare plans that cover over 56% of all MA lives and our technology powers conversations with millions of members every month. Here’s what we are seeing and hearing about the changes to Star Ratings: 

Engagement strategies must center around CAHPS, not just include it. 

Most engagement strategies that seek to improve Star Ratings tend to focus on outcome and process measures, where specific member actions are vital to success. Engaging members about refilling prescriptions, completing important screenings, and managing chronic conditions to impact HEDIS and Medication Adherence-based measures has been the primary approach for many plans for years. Plans now must think beyond the action-based use cases and think about engagement as a core part of relationship-building with their members. CAHPS-specific solutions, such as off-cycle surveys or conversational follow-ups after provider visits are moving to the forefront in our customers’ strategies. Simply asking members about their experiences at scale can both provide powerful insights and opportunities to connect members to more resources and help. Plans are using automated conversations and data analytics to measure sentiment and intent of member responses to text messages to find “hotspot geographic areas and “hot topics” where negative (or positive) sentiment is clustering.  We are also seeing more customers use Conversational AI and our browser-based Engagement Console to enhance existing member services team efforts to provide concierge-level help to members, as plan navigation becomes more important to boosting member experience.  

But plans cannot ignore the unchanged measures. 

Medication Adherence and HEDIS are still going to have a major impact on overall ratings. So as plans correctly look to focus more resources and effort on Experience and Complaints measures, they also need to find ways of achieving or maintaining high ratings in those areas efficiently and at scale. For our customers, that has meant using Conversational AI-enabled outreach to deliver automated prescription refill dialogues or start tailored conversations designed to help close gaps-in-care. And since these are really conversations – with members welcomed to respond back – we can actually hear about barriers, difficulties, and frustrations members may experience in completing those actions. That data is invaluable in helping shape and refine a CAHPS strategy. Because an experience-centric strategy makes every member touchpoint – even a refill reminder – an opportunity to learn from and connect with the population. 

One thing does not change: Stars continue to drive the engagement strategy. 

The outlier deletion process will have a wide impact. For engagement, it means that Stars will become even more competitive, and deploying solutions that make a real impact will move from being a goal for most MA plans to an absolute necessity. Outreach that can reach people at scale and still provide a personal, conversational experience will be crucial, as will finding ways to reach members who aren’t engaging with existing channels. mPulse is seeing plans get on the front foot: proactively starting conversations with their members about their benefits and health at massive scale. And with the COVID-19 crisis, these plans are finding members especially eager to learn about their healthcare and how their plan can help them. Building that relationship now will help these plans down the road, when they need to activate members to close a care gap, or when a member who received a tailored and helpful text message receives a CAHPS survey months later.