Compliance & security
The program has to hold up when someone checks.
Remote monitoring attracted a lot of vendors whose product is a scale and an invoice. Enforcement noticed. Titra Health is built on the opposite assumption: that the work will be examined, so the record has to be complete, attributable, and produced from something that cannot be quietly rewritten.
The posture
Six commitments, enforced in code.
Patient-reported data can never become a claim
CMS pays the device-supply codes only for data automatically transmitted from a device meeting the FDA definition. In Titra Health, self-reported numbers are clinical context and are structurally incapable of counting toward a transmission day or a billing line. In June 2025 the DOJ settled a case for $1.29M on exactly that fact pattern.
The minutes have to actually happen
Time logs are append-only with staff attribution and a required activity note. Corrections void and re-insert. There are no auto-timer durations, no screen-open time, no event-to-event deltas — the platform makes documenting easy and never makes it optional.
Role matters to the arithmetic
Admin staff can run device logistics and enrolment paperwork, and their minutes are excluded from 99457 and 99490 because CMS excludes them. The engine enforces this rather than trusting the roster.
A snapshot you can still produce in three years
Monthly reports render from frozen snapshots, so a re-download is identical months later. Webhook events are retained forever — that payload is the audit evidence that a reading was device-transmitted.
Built as a business associate from day one
A dedicated AWS account under a signed BAA, KMS-encrypted database in private subnets with point-in-time recovery, no SSH, admin access through Session Manager only, mandatory MFA, and an access log on every PHI read.
You bill, under your own NPI
Titra Health never bills Medicare — RPM management codes are E/M codes and CMS rejected vendor billing. It charges a flat monthly fee per enrolled patient, owed regardless of collections, never a percentage. That is the structure the Anti-Kickback Statute allows.
Guardrails
Some things are meant to be impossible.
A guardrail you can switch off is a suggestion. These are structural — the schema and the engine refuse them, not a setting.
What the platform will not let you do
- Count a patient-reported number toward a transmission day or a claim line
- Silently edit or delete a time log once written
- Count administrative staff minutes toward 99457 or 99490
- Bill a device code the transmission days do not support
- Auto-close an alert without a documented human response
- Submit a claim for a patient whose coverage failed re-verification
What Titra Health is not
- A biller — your practice submits under its own NPI
- A provider of clinical staff — your team furnishes the minutes
- A percentage-of-collections vendor — the fee is flat per enrolled patient
- An AI that decides what is billable — eligibility is deterministic and unit-tested
- A channel for PHI by email, SMS or push
- Joined to Titra Health’s consumer app — the two hold separate data, by design
Security
Where the data actually sits.
Dedicated environment, signed BAA
Clinic data lives in its own cloud account under a signed business-associate agreement, on HIPAA-eligible services only.
Encrypted, private, recoverable
The database sits in private subnets with no public route, encrypted at rest with managed keys, with automated point-in-time recovery and longer-horizon snapshots kept for the audit era.
No shell access
There is no SSH port. Administrative access happens through brokered, logged sessions — so there is no standing key to lose or reuse.
Mandatory MFA, no exceptions
Every account carries a second factor. Logins, failures, lockouts and password resets append to an immutable auth trail.
Access logged per read
Every read of patient data writes an access-log row naming the user and the record. Who looked at what, and when, is a query rather than an investigation.
Least data, on purpose
The chart holds what the program needs and refuses what it does not. No Social Security numbers, no Medicare beneficiary identifiers.
Documentation available on request. The security risk analysis, written HIPAA policies, breach-response plan, vendor BAA register and go-live checklist are maintained as part of the program and shared with practices under a mutual NDA during diligence. Ask at team@titrahealth.io.
How we charge
A flat fee per enrolled patient. Never a share of what you collect.
Titra Health charges a fixed monthly amount for each enrolled patient, owed whether or not the claim is paid. That is deliberate, and it is the part of the arrangement a compliance officer should look at first.
A vendor paid a percentage of collections has a financial interest in more codes going out the door, which is precisely the structure the Anti-Kickback Statute is concerned with. A flat fee removes that interest: Titra Health earns the same whether a patient’s month bills at 99454 or does not bill at all — so the engine has no reason to tell you anything but what the record supports.
Practices bill Medicare themselves, under their own NPI. Titra Health legally cannot bill these codes, and does not try to.
Send your compliance questions first.
We would rather answer the hard ones before a demo than after a contract. Bring your compliance officer.