Data Monitoring and Medical Billing Terms and Conditions


a. Clinical Staff Review.HWS’s Clinical Staff (defined below) will review Participating Patient data collected by Devices, Participating Patient answers to questionnaires, and incoming Participating Patient calls Patient App on an ongoing basis between the hours of 8:00 am and 5:00 pm Eastern Time (ET), five (5) days per week (“Business Hours”). During Business Hours, HWS Clinical Staff will provide Customer with notification under the Participating Patient escalation Clinical Protocol. For each Participating Patient,
HWS will let the designated Clinical Contact (defined below) know if/when intervention, including the reason for escalation, is needed through the Care App and Provider-facing Dashboard.
b. No Emergency Monitoring. HWS is not responsible for the accuracy of any data transmitted or monitored. Further, Clinical Staff services are not intended to provide 24-hour monitoring or to identify medical emergencies and cannot be used or construed as such.
c. Medical Billing Services. HWS will submit claims to Medicare on behalf of Customer only for CPT codes 99453, 99454, 99457, 99458, and 99091 (the “RPM Codes”), 98975, 98976, 98977, 98980, 98981, and 98978 (the “RTM Codes”), G0506, 99490, 99489, and 99487 (the “CCM Codes”), and 99212 and 99215 (the “Telemedicine Codes”), as applicable, with respect to Participating Patients (“Medical Billing Service(s)”). HWS will not submit claims for other codes or services provided by Customer to Participating Patients or otherwise, and HWS will not be responsible to Customer for Customer’s failure to receive reimbursement for any submitted claims for reasons outside of HWS’s control.


a. Identify Clinical Contact. Customer is responsible for identifying a point of contact (“Clinical Contact”) within Customer’s practice to remain available to communicate with HWS as needed. There must be at least one Clinical Contact available at all times during Business Hours to be responsible for taking calls from HWS Clinical Staff and escalating interventions to a physician, as necessary.
b. Identify Clinical Protocol. Customer is responsible for establishing monitoring parameters for each Participating Patient via the Software and must enter relevant parameters for each Participating Patient enrolled in the Services. Customer is solely responsible for the accuracy and appropriateness of these parameters. HWS Clinical Staff will monitor PHI according to the parameters established by the Customer.
c. Identify Participating Patients. Customer is responsible for identifying high-risk patients who will benefit from Virtual Care Services and providing HWS with required Participating Patient information including but not limited to Participating Patient demographic information, insurance information, disease state, and other data required by HWS to enroll Participating Patients.
d. Obtain Consent from Participating Patients. Customer is responsible for obtaining face-to-face Participating Patient consent to participate in the Services as required by and defined by The Centers for Medicare and Medicaid Services (“CMS”). Customer shall obtain and document this consent and any other necessary patient consent, authorization, or other agreements that are required to enroll a Participating Patient in the Services.
e. Patient Copay and Deductible. Customer is responsible for collecting any required patient copay, coinsurance, or deductible required by the Patient Participant’s health insurance plan.
f. Participate in Rapid Enrollment of Participating Patients. Customer and Authorized Users must participate in the HWS Rapid Enrollment process. This includes but is not limited to, providing all required recordings for patient Rapid Enrollment, and attending patient review meetings initially and at thirty (30), sixty (60), and ninety (90) day intervals throughout the patient Rapid Enrollment period.
g. Supervision. Customer is responsible for General Supervision of HWS Clinical Staff as needed, where “General Supervision” is defined as a physician or other billing provider providing overall direction and control in accordance with applicable billing requirements set forth under Medicare. Under General Supervision, Customer remains ultimately responsible for oversight of the monitoring services.
h. Electronic Medical Record Access and Documentation.

i. Access for Patient Identification and Onboarding. Customer is responsible for providing HWS with view-only administrator-level access to the Customer’s Electronic Medical Record (“EMR”) and Electronic Practice Management Software to provide HWS with patient demographic, patient data required to provide the Services, and insurance information in a Consolidated-Clinical Document Architecture (C-CDA) or comma-separated values (CSV) electronic format to assist HWS and Customer in identifying and enrolling Participating Patients. Customer is responsible for ensuring the accuracy, quality, integrity, legality, reliability, and appropriateness of data accessed through the Customer’s EMR. ii. Access for Medical Billing Services. Customer will provide access to its Electronic Medical Record (“EMR”) and Electronic Practice Management Software to HWS and its subcontractor(s) as necessary to allow HWS to provide Medical Billing Services. If Customer’s EMR is not compatible with HWS’s billing practices or processes, Customer will work with HWS and its subcontractor(s) to integrate its billing system with HWS’s billing practices and processes as necessary to allow HWS to provide the Billing Services.

i. Provide Patient Escalation Protocol. Customer will provide HWS with a written patient escalation protocol without unreasonable delay and within five (5) business days of the Order Form. j. Provide Credentialing Access. Customer must provide HWS and its subcontractor(s) with credentialing access and all necessary and reasonably requested documentation to allow for HWS and subcontractor(s) to submit claims to health insurance providers, including Medicaid and Medicare on Customer’s behalf (“Documentation”). Such Documentation may include without limitation Customer’s National Provider Identifier (“NPI”), Provider Transaction Access Number (“PTAN”), and/or Customer’s Tax Identification Number (“TIN”). Customer is responsible for confirming the accuracy and completeness of all documents and information provided. k. Claim Approval. Customer is responsible for approving all claims submitted by HWS to healthcare insurance providers, including Medicare and Medicaid

l. Medical Treatment and Advice. Customer is responsible for making all treatment decisions and providing medical care with respect to all Participating Patients and any escalations forwarded to Customer by HWS. HWS and its Clinical Staff are not medical providers and are not intended to replace the relationship between Participating Patients and their healthcare provider(s). HWS CAN NOT BE HELD RESPONSIBLE FOR SUB-STANDARD TREATMENT OR MEDICAL MALPRACTICE WITH RESPECT TO ANY PARTICIPATING PATIENT. Please review the Software License & General Terms and Device Terms & Conditions for additional disclaimers.


a. Commencement of Services. HWS will commence Services within thirty (30) days of the start date indicated on the Order Form.
b. Clinical Staff. HWS will provide appropriately trained and qualified personnel to monitor Participating Patient data.
c. Virtual Care Management Services. HWS will provide Virtual Care Management Services as indicated on the Order Form to include Remote Patient Monitoring (“RPM”), Remote Therapeutic Monitoring (“RTM”), and/or Chronic Care Management (“CCM”) services, as defined by CMS. HWS Clinical Staff will perform RPM, RTM, or CCM data collection by collecting biological data electronically from Devices that monitor Participating Patients. HWS Clinical Staff will manage collected data, provide alerts to the Customer’s Authorized User, and send information to the Customer based on predetermined patient intervention and escalation protocols.
d. Care Manager. HWS will assign a Care Manager from the multilingual, international call center to monitor Participating Patient use of the Device, to speak with Participating Patients as necessary, and provide non-clinical intervention or escalation where necessary.
e. Reimbursement and Coding. The HWS Care Manager will accurately code the professional services rendered by Customer and HWS under the terms of this agreement. HWS will ensure that the Care Manager is trained and remains up-to-date on coding accuracy as consistent with industry standards.
f. Revenue Cycle Management. HWS will provide revenue cycle management and medical coding support services. Under these Data Monitoring and Medical Billing Terms & Conditions, HWS will work with a billing vendor to use data from the HWS Platform and the Customer’s EMR to bill appropriate healthcare insurance, Medicare, and Medicaid services for care enabled through HWS’s Platform and Services.
g. Customer Training. HWS will provide Clinical Staff for a maximum of two (2) eight-hour (8-hr) days to provide training and Device education to the Customer and Customer’s Authorized Users. Additional training rates: (In-person: $100 USD/hour & Remote: $50 USD/hour)

h. Correction of Mistakes. HWS and its subcontractor(s) will reasonably correct any mistakes on an original claim submission that HWS is responsible for and that result in denial of reimbursement, provided that such mistake is not due to an inaccuracy in the Documentation or otherwise made at the fault of Customer.


Customer will pay to HWS the Clinical Staff Services fees in accordance with the terms indicated on
the applicable Order Form, Service Rates outlined in Appendix A: Service Costs, the Device Terms & Conditions,
and the Software License & General Terms.