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DIME PROJECT

Aging in Place of Choice with Connected Health Technologies

From AgeTech innovation to sustainable implementation

AGETECH DEVELOPER: COMMERCIAL STRATEGY

Building a business that can reach older adults

A common reason AgeTech products fail commercially is a mismatch between who uses the product, who benefits from it, and who pays for it. A company building a direct-to-consumer product marketed solely to older adults may miss business opportunities by not recognizing that in many cases, the actual purchaser is an adult child or care partner. On the other hand, selling to businesses like health systems can fail if you underestimate a long 9- to-18 month sales cycle and the strong proof of financial return they demand.

This section walks you through the key decisions involved in building a commercial strategy for your product. You’ll identify the buyer(s) relevant to your product, consider how your business model influences regulatory and reimbursement pathways, and explore what it takes to successfully bring your solution to market.

Start with the question that determines almost everything else:

Who decides to buy?

IDENTIFY YOUR BUSINESS MODEL

Who decides to buy your technology?

Incorporate decisions about your business model in parallel with product design. Who you sell to and how you get paid are design decisions to be resolved alongside product development, not after the product is built.

If the person who decides to pay for the technology is the person who uses it or knows the person who will use it, you likely follow a business-to-consumer or direct-to-consumer (B2C / D2C) pathway →

If you’re targeting a clinic, health system, insurance plan, ACO, PACE organization, or Medicaid HCBS waiver program to pay for or contract your product, even if an older adult or care partner is the end user, you are closer to a business to business to consumer (B2B2C) pathway →

If you’re not sure, or you’ve assumed “the older adult” without testing who actually holds the credit card or signs the contract: STOP HERE. That uncertainty is the single most common root cause industry experts report in early-stage failure.ⓘInsights from a DiMe workshop activity exploring reasons for AgeTech start-up failure among experts (n=36) representing a group of AgeTech developers, healthcare providers, academic-led incubators for AgeTech companies, and other health and aging enablers.Resolve it before reading further. The two branches below require different capital, timeline, and evidence strategies, and building against the wrong one is expensive to discover late. 

B2C / D2C — “I’m selling to the older adult or their care partner directly.”

⚠ The core risk: burning through capital before discovering your customer acquisition strategy is structurally unviable.

“Startups spend [hundreds of thousands of dollars] before discovering their acquisition model is structurally unviable.”

– AgeTech developerⓘ Quote from a DiMe-led workshop with AgeTech experts. Quoted with permission

Why AgeTech is harder than standard consumer health D2C:

  • The purchaser is often an adult child or care partner, not the older adult, meaning your messaging has to work for multiple audiences with potentially different priorities. Marketing and advertising directly to older adults and families can get expensive quickly if you don’t have the right messaging or you haven’t optimized your marketing and customer acquisition channels.
  • The older adult’s own resistance to adopting new technology, which is often driven by concerns about identity, autonomy, and privacy rather than by the product’s actual function (see our data repository of lived experience to dive deeper). This adds conversion friction unique to AgeTech products, potentially increasing funnel drop-off that may have nothing to do with your ad creative or landing page.ⓘ >64% of adults 50+ don’t feel today’s technology is designed with their age in mind, and 60% cite cost as a barrier to purchase while 41% cite reliability concerns (source: AARP)
  • Trusted referral channels matter more than paid advertising for older adults. A referral from a primary healthcare provider, family member, or trusted community organization converts differently than a cold paid click, but building that channel takes longer than a paid advertisement on social media, for example.

“$100-300 per older adult customer… and that is after a refined marketing algorithm with large target user datasets. A new entrant without that data infrastructure should budget higher, not lower.”

– AgeTech developerⓘ Quote from a DiMe-led workshop with AgeTech experts. Quoted with permission

Sales cycle: This could be weeks to months for an individual purchase decision. To build a real business, you need more than just a handful of customers. Getting customer volume requires either spending chunks of money continuously on digital ads or getting doctors, eldercare managers, and senior centers to recommend your product. Neither of those channels is fast or cheap to build.

Every AgeTech company’s customer acquisition cost will look different, but start by assessing whether you already have a proprietary or licensed dataset for targeting this older adult segment. For example, do you already have access to a pre-built list or mechanism to identify and reach older adults, such as a partnership with an advocacy group (like AARP), a senior living community, or a specialized database?

If you’re starting from zero, budget high for customer acquisition cost and validate it with your own early spend before assuming it will hold. Run live, small-scale ad tests early to discover your real conversion costs before raising money or scaling up.

Buyer(s) primary drivers and key motivators:

BUYER PRIMARY DRIVERS & MOTIVATIONS HOW TRUST IS GAINED
Older adult (self-pay) Independence, autonomy preservation, dignity, non-stigmatizing aesthetics Usability, ease of installation, trust
Adult child or other family care partner (self-pay) Peace of mind, safety monitoring, remote reassurance, ease of monitoring without conflict

Note a potential tension point: these two decision-makers frequently have opposing priorities: the family wants more surveillance, the older adult may want less.

B2B2C — “I’m contracting with a clinic, health system, ACO, Medicare, PACE organization, or other institutional buyer.”

⚠ The core risk: sales cycle length kills the runway before scale is reached.

“6+ months with a payer is doing well.”

– AgeTech developerⓘ Quote from a DiMe-led workshop with AgeTech experts. Quoted with permission

What makes the AgeTech buyer landscape different from general digital health?

  • Medicare Landscape: B2B2C AgeTech operates largely  within the highly regulated, multi-layered Medicare ecosystem. This means sales cycles are bound to strict federal calendar deadlines, state-level licensing, multi-contract procurement tracks (like D-SNPs), and evolving CMS payment models (like CMMI’s ACCESS model).

  • Medicare Advantage plans work against a fixed annual deadline, the first Monday in June, when they must submit their supplemental benefit bids to CMS for the following plan year. If your product isn’t locked into a plan’s bid by that date, the next opportunity is a full year away.

  • Dual Eligible Special Needs Plans (D-SNPs) can serve dual eligible older adults (eligible for Medicare and Medicaid). D-SNPs a Medicare Advantage contract with CMS and a contract with the state Medicaid agency. In integrated D-SNPs, the same organization also covers Medicaid benefits, so selling in may mean two internal buying functions Selling into this segment generally means navigating two internal buying functions within the same insurer rather than clearing two government procurement tracks yourself. The Medicare Advantage side owns supplemental benefits and Star Ratings priorities, while the Medicaid or long term services and supports side owns home and community-based services and care management, funded through the state contract. Practically, this means an AgeTech company pitching a plan sponsor for their product may need two separate conversations and two separate business cases.

  • Program of All-Inclusive Care for the Elderly (PACE) organizations operate under a signed agreement with CMS and the state administering agency, and in some states, such as New York, must also hold a separate state license. Eligible participants are 55 or older, meet their state’s nursing facility level-of-care standard, live in the PACE organization’s service area, and can live safely in the community despite needing that level of care. Most are full benefit dual eligibles, since Medicaid and Medicare together fund the bulk of the capitated rate.
    For most AgeTech products, you do not need your own state license or program agreement. You typically sell as a vendor to an entity that already holds those approvals, so the buying process runs through the PACE organization’s procurement and compliance review rather than a separate government track for you.

  • CMS ACCESS. If your product targets older adults with chronic disease outcomes such as blood pressure, diabetes, chronic pain, or depression, the CMS ACCESS Model is a program pathway worth tracking, since it pays participating providers for measurable improvement using technology-enabled care. Worth noting before you build a business case around CMS ACCESS: published rates run from about $7.50 to $35 (as of October 2026) per beneficiary per month depending on the clinical track, and half of that is withheld until the participant hits its outcome targets, so payment is effectively at risk rather than guaranteed. At that per patient rate, the model tends to favor organizations that can enroll and manage a large panel of patients efficiently, which makes it a tougher fit for smaller AgeTech companies unless they can operate at real scale or partner with a provider organization that already has one.

Map your target buyers and their core purchasing motivations early. This will shape both your business strategy and stakeholder pitches. The table below outlines examples of key decision-makers across each organization type. While securing a pitch meeting is a crucial first step, always research individual decision-maker motivations you’re meeting with beforehand to tailor your message effectively.

BUYER PURCHASE DRIVERS & MOTIVATION KEY EVIDENCE REQUIREMENT KEY DECISION-MAKERS & MOTIVATIONS EXAMPLES
ACO

Risk reduction and prevention, readmission avoidance

Clinical outcomes data, ROI

 Chief Medical Officer: needs data tied to shared savings benchmarks;
CFO/VP Finance: wants per-member-per-month cost offset modeling;
Care Management Director: needs proof it reduces their team’s caseload burden, not adds to it
Medicare Advantage plan and other risk-bearing entities Improving Stars Ratings, cost avoidance; reduction in in-patient utilization HEDIS-relevant endpoints, ROI modeling Chief Medical Officer: improvement in STARS ratings/HEDIS measures;
VP STARS/Quality Improvement: demonstrate direct line to bonus payment impact;
Supplemental Benefits Manager: fit within SSBCI (Special Supplemental Benefits for the Chronically Ill) flex-card or in-home benefit categories;
Actuarial/Finance: bid impact modeling
New CMMI Models (e.g., ACCESS, GUIDE) Improvement against outcome-aligned payments Clinical outcomes data, ROI Model Implementation Lead: needs to demonstrate alignment to specific model payment triggers;
Grants/Compliance Officer: audit trail and reporting cadence compliance
PACE organization Capitated cost management Functional outcomes, caregiver burden, ROI

Interdisciplinary Team (IDT) Lead/Medical Director: clinical appropriateness within capitated budget;
Day Center Operations Director: practical concern about whether tech reduces or increases transport or staffing needs;
Finance Director: per-participant capitation math makes sense
Health system Revenue generation through RPM + service volume back to the health system, readmission avoidance Clinical outcomes data, ROI

VP Ambulatory/Population Health: readmission penalty avoidance (HRRP);
RPM Program Director: billing workflow (CPT 99453/99454/99457/99458) and clinician time burden;
CFO/Revenue Cycle: net new reimbursable revenue vs. cost of monitoring staff;
CMIO/IT Security: EHR integration and data governance

CASE STUDY

Reducing avoidable acute care through passive in-home sensors

Sensorum reported that combining fully-passive in-home sensors with remote nurse triage effectively reduces acute care utilization, achieving a 34% reduction in hospital admissions and a 28% drop in ER visits in its partnership with Intermountain Health. This approach strengthened their business case to risk-bearing clinics by allowing them to scale continuous senior care without ballooning per-patient costs while directly aligning financial incentives with patient outcomes through fees-at-risk contracts.

View case study

REGULATORY STRATEGY

Let your regulatory decisions be informed by business model & strategy early on

Determine your intended use and context of use.

Whether your AgeTech solution is a general wellness product or an FDA-regulated device, the starting point is the same.

Intended use provides a general description of what your digital health product does, including indications for use and additional information about the disease, condition, environment, and patient population.

Source: DiMe’s Quick Guide on Intended Use and Indication for Use for Digital Health Products.

Context of use is a statement that fully and clearly describes how the product is to be used and the purpose of the use.

Source: NIH Glossary

Determine whether your product is a wellness product, a non-device clinical decision support (CDS), or medical device.

General wellness products
  • Do NOT make any reference to diseases or conditions: their intended use relates to maintaining or encouraging a general state of health or health activity; OR
  • MAKE a reference to diseases or conditions but only to sustain or offer general improvements in function associated with a general state of health; they promote healthy lifestyle behaviors that may help reduce the risk of or help living with certain chronic diseases or conditions; AND
  • ARE low risk

QUICK LINK: FDA GUIDANCE | General Wellness: Policy for Low Risk Devices

Non-device clinical decision support (CDS)

Meets ALL of the following:

  • Do NOT acquire, process, or analyze a medical image or a signal from an in-vitro diagnostic device or a pattern or signal from a signal acquisition system; AND

  • Display, analyze, or print medical information about a patient or other medical information; AND

  • Support or provide recommendations to a healthcare professional (HCP) about prevention, diagnosis, or treatment of a disease or condition; AND

  • Enable an HCP to independently review the basis for the recommendations that such software presents so that it is not the intent that the HCP rely primarily on any such recommendations to make a clinical diagnosis or treatment decision regarding an individual patient

  • Note that non-device CDS applies only to software intended for healthcare professionals. Software aimed at patients or caregivers can’t qualify

QUICK LINK: FDA GUIDANCE | Clinical Decision Support Software

Class I-III medical device

If appropriate, determine your product’s medical device classification according to section 201(h) of the FD&C Act, and if so, its classification under section 513.

QUICK LINK: FDA | How to Determine if Your Product is a Medical Device

This determination directly affects reimbursement. Products that meet the FDA definition of a medical device may be eligible for pathways such as Remote Patient Monitoring (RPM) and, where applicable, DME coverage. General wellness and non-device clinical decision support (CDS) products typically do not qualify for these device-based pathways, but may have other routes to market, including direct-to-consumer sales, health system or provider contracting, value-based care arrangements, and coverage through Medicare Advantage, D-SNP, or PACE programs. (see next section).

Build an evidence generation plan to support your outcome claims, usability, privacy, and security.

Whether that includes evidence to support medical claims or other functional, health claims made by wellness or CDS products, or evidence on usability, privacy and security, your data collection approach should be informed by the following.

FTC logo

Privacy and security requirements apply regardless of regulatory pathway, but HIPAA and the FTC Act apply in different ways. HIPAA generally applies to covered entities and their business associates, while the FTC Act applies more broadly to companies that collect, use, or share consumer health information and can apply even when HIPAA does not. Also consider applicable state privacy laws and, increasingly, security standards such as SOC 2 or HITRUST, as part of health system procurement.

REIMBURSEMENT STRATEGY

Find the reimbursement pathway that fits your business model

The pathways below cover the reimbursement and revenue routes AgeTech developers most commonly pursue: remote patient monitoring, chronic care management, CMMI models (ACCESS), Medicaid HCBS waivers, Medicare Advantage supplemental benefits, PACE program and D-SNPs, and direct-to-consumer or cash-pay. Each pathway reports whether the pathway is billable today or still emerging, so you can weigh it against your own runway.

If you arrived from the B2B2C pathway, many of these pathways apply directly to your buyer landscape. If you arrived from B2C / D2C pathway, the direct-to-consumer entry picks up where your cost and sales cycle detail left off.

Remote Patient Monitoring (RPM)

✓ Billable Today

Remote Physiologic Monitoring: tracks biometric data like blood pressure, weight, and glucose. CPT codes 99453, 99454, 99457, 99458.

RPM reimburses clinicians for collecting and interpreting biometric data (e.g., blood pressure, weight, glucose, oxygen saturation) transmitted automatically from a patient’s home medical device. The billing practitioner (physician, NP, or PA) claims the CPT codes; the AgeTech developer’s revenue flows from the provider relationship, not from CMS directly.

How developers get paid

Developers sell or lease the device and software to a provider practice, which then bills CMS and pays the developer through a per-patient subscription or revenue-share arrangement. The provider must bill, and developers cannot claim RPM codes directly.

Best fit for

Hardware-enabled monitoring companies producing FDA-defined medical devices like connected blood pressure cuffs, pulse oximeters, weight scales, continuous glucose monitors that are bundled with a software platform that automates data transmission and supports clinical documentation. RPM is NOT accessible to general wellness apps or consumer fitness trackers, which do not meet the FDA device definition.

KEY ELIGIBILITY CRITERIA
  • Established patient-provider relationship before monitoring begins.
  • Documented patient consent.
  • Monitoring
    must be medically reasonable and necessary.
 REGULATORY AND EVIDENCE REQUIREMENT Devices must meet the FDA’s legal definition of a “medical device.” Data must transmit automatically; CPT 99454 requires 16 or more days in a 30-day period, and CPT 99445 covers 2 to 15 days. Manual entry does not qualify.
PRIMARY FAILURE POINTS
  • Building on a device that doesn’t meet the FDA device definition. This structurally blocks billing.
  • Assuming the vendor bills CMS directly; in practice, the provider bills, and the vendor’s revenue depends on that provider relationship.

Sources: CMS Telehealth Services MLN Fact Sheet (Dec. 2025); CMS MLN901705 “Telehealth & Remote Patient Monitoring” (Apr. 2025).

⚠ Proposed Rule: CMS 2027 Physician Fee Schedule

A draft rule proposed in July 2026 would restrict Medicare RPM and RTM billing to clinical staff directly employed by the billing practice, effective January 1, 2027. If finalized, third-party vendor billing arrangements would no longer qualify under Medicare fee-for-service. This poses a direct threat to business models that rely on practice partners billing on a developer’s behalf. 

The rule is not yet final. Monitor the final rule expected in November 2026, and model alternative pathways (CMS ACCESS strategy, MA supplemental benefits, PACE capitation, HCBS waivers) in parallel.

View DiMe’s comment on the proposed rule

Chronic Care Management (CCM)

✓ Billable Today

CCM reimburses clinicians for non-face-to-face care coordination for patients managing two or more chronic conditions expected to last 12 months or longer. Unlike RPM, CCM is a care-coordination service, not a device-dependent billing pathway. There is no FDA device requirement, which broadens the range of AgeTech products that can support it. CPT codes 99490, 99439, 99491, 99437, 99487, 99489.

How developers get paid

Developers sell software platforms, care navigation tools, or care coordinator support services to provider practices, which then bill CCM codes and pay the developer through a subscription or per-patient fee. CCM is frequently sold alongside RPM. This means the same patient can generate revenue under both code sets simultaneously, improving the economics of both programs and making the combined pitch more attractive to practices.

Best fit for

Care coordination platforms, digital care management tools, AI-assisted patient outreach and monitoring software, and medication adherence solutions that support care plan documentation and time tracking without requiring a connected hardware device. Also well-suited for companies building combined RPM + CCM offerings for primary care and multi-specialty practices.

KEY ELIGIBILITY CRITERIA

  • The patient has 2+ chronic conditions expected to last at least 12 months or until death. The chronic conditions must also “place the patient at significant risk of death, acute exacerbation or decompensation, or functional decline”
  • Documented consent (verbal or written) before services begin.
  • Services furnished under a billing practitioner’s oversight.

REGULATORY AND EVIDENCE REQUIREMENT

  • Evidence collected needs to be fit-for-purpose based on clinical outcomes intended to prevent, maintain, and/or improve. 
  • Requires a documented care plan, time tracking, and patient consent.
  • No FDA device requirement.

PRIMARY FAILURE POINTS

  • Under-resourcing documentation and audit readiness. OIG added an active Work Plan audit in March 2026 reviewing whether billed patients actually meet the two or more chronic conditions eligibility requirements, with vendor oversight of outsourced programs as one specific area of focus.
  • Assuming the vendor bills directly rather than enabling practice billing (same structural issue as RPM).

Sources: CMS 2026 Physician Fee Schedule Final Rule; CMS MLN909188; ChartSpan, “Chronic Care Management CPT Codes & Billing Guide” (2026); CCM Health, OIG 2026 Work Plan coverage.

CMS ACCESS Model

⏳ Emerging – limited access

The Advancing Chronic Care with Effective, Scalable Solutions (ACCESS) Model pays participating care organizations based on whether patients achieve measurable health improvements, not based on the volume of services delivered. First cohort launched July 5, 2026. Unlike fee-for-service pathways, this model rewards outcomes, which means developers whose products generate documented clinical improvement have a direct stake in the payment mechanism, but the pathway to revenue is indirect and longer than any other option on this list.

How developers get paid

As an AgeTech developer, you can partner with a CMS-selected participating care organization or if you are a Medicare Part B-enrolled organization with a designated physician Clinical Director you can participate in ACCESS directly.

Your product must demonstrably help improve outcomes of interest for outcome-aligned payment (OAP). Note, if you partner with a CMS-selected participating care organization, commercial arrangements are negotiated bilaterally, typically a per-patient subscription or outcomes-linked fee paid by the participating organization from its ACCESS revenue.

Since 50% of ACCESS payments are withheld and reconciled after 12 months based on the organization’s Outcome Attainment Rate, the participating organization’s cash flow is also deferred, meaning developers who tie their fees to ACCESS revenue need to model for that lag.

Best fit for

Companies with strong clinical outcome evidence in the four ACCESS tracks: early and advanced cardio-kidney-metabolic disease, musculoskeletal conditions, and behavioral health.

KEY ELIGIBILITY CRITERIA

  • Applications opened on a rolling basis in January 2026; Must partner with, or become, a CMS-selected participating organization. 

  • The program is not directly accessible to technology vendors.

REGULATORY AND EVIDENCE REQUIREMENT

  • Measurable health outcomes tied to each patient’s individual baseline. Payment is tied to demonstrated improvement, not activity volume.

  • No billing track record yet exists to benchmark against.

  • No FDA device requirement.

PRIMARY FAILURE POINTS

Finalized 2026 to 2027 annual allowed amounts range from $90 to $420 depending on track and payment tier (initial vs follow on period, working out to roughly $7.50 to $35 per beneficiary per month, and the participating organization only gets full payment if at least half its aligned beneficiaries meet their individual outcome targets. At that rate, the model favors organizations that can manage a large panel efficiently, and the modest, partly at risk payment should factor directly into whether the economics work for your product.

Sources: CMS ACCESS Model (2026); CMS ACCESS Model payment amounts and performance targets, (Effective Period: July 5, 2026 – December 31, 2027)

Medicare Advantage Supplemental Benefits (SSBCI)

✓ Billable today (plan-dependent)

Medicare Advantage plans can cover non-medical and technology-enabled products for members through Special Supplemental Benefits for the Chronically Ill, a benefit category Congress created in the 2018 Bipartisan Budget Act. Unlike RPM or CCM, there is no CPT code or claim involved. The plan simply includes the benefit in its CMS-approved annual bid and pays the vendor directly as part of its overall benefit spend.

How developers get paid

Developers contract directly with the Medicare Advantage plan, typically through a per-member-per-month or per-unit licensing fee negotiated as part of the plan’s supplemental benefit vendor relationships. There is no CMS intermediary and no claims submission. The plan funds the benefit from its own rebate dollars set during the annual bid process, so the commercial relationship looks more like a B2B vendor contract than a reimbursement pathway.

Best fit for

Companies with a product tied to a defined chronic condition category, such as fall prevention systems, remote monitoring for cardiometabolic conditions, medication adherence tools, home safety sensors, or nutrition and food delivery services. Less suited to general wellness products aimed at the whole Medicare population rather than a chronically ill subgroup, since SSBCI is targeted by design.

KEY ELIGIBILITY CRITERIA

  • Product must fit an existing supplemental benefit category CMS recognizes, either standard primarily health-related benefits or SSBCI for chronically ill enrollees.

  • For SSBCI specifically, the health plan must determine each member is a chronically ill enrollee, meaning they have one or more complex chronic conditions, are at high risk of hospitalization or other adverse outcomes, and require intensive care coordination.

REGULATORY AND EVIDENCE REQUIREMENT

  • Plan must maintain a bibliography of evidence showing the benefit has a reasonable expectation of improving or maintaining health or function. No FDA device requirement.

  • No FDA device requirement.

PRIMARY FAILURE POINTS

  • Missing the annual MA bid cycle. Benefits are locked in during the prior spring’s bid submission, so a pitch made mid-year usually can’t launch until the following plan year.
  • Pitching a general wellness story instead of a chronic illness story. SSBCI eligibility is condition-specific, so the sales case needs to name the qualifying conditions your product addresses.
  • Showing up without evidence. A plan needs citable sources to meet its bibliography requirement, not just a product demo or a customer testimonial.

Sources: CMS Special Supplemental Benefits for the Chronically Ill guidance (via ODPHP Food is Medicine Federal Resource Hub; KFF Medicare 101; Medicare Advantage and other health plans

PACE and D-SNP (dual-eligible programs)

✓ Billable today – no per-code billing required

The Program of All-Inclusive Care for the Elderly (PACE) provides fully integrated Medicare and Medicaid services to nursing-home-eligible adults living in the community under a single capitated rate. Because PACE owns the full cost of care for each enrolled participant, every avoided hospitalization, ED visit, or institutional placement is a direct financial gain for the organization. There are no CPT codes to bill, no annual bid cycles to hit, and no waiver amendment processes to navigate. Dual Eligible Special Needs Plans (D-SNPs) operate on structurally similar capitated logic for dual-eligible Medicare-Medicaid enrollees and are included here as a comparable pathway.

How developers get paid

Developers negotiate a per-participant-per-month fee directly with the PACE organization. There is no CMS intermediary and no provider billing infrastructure required on the developer’s side. The commercial conversation centers on a single calculation: does the technology’s monthly cost per participant come out ahead of the hospitalization or ED visit cost it is expected to prevent? Contracts are negotiated at the organizational level, pilots move faster than health system procurement cycles, and PACE interdisciplinary team (IDT) staff (such as physicians, nurses, social workers, physical therapists) are directly involved in evaluating and championing new tools, which shortens the path from pilot to renewal.

Best fit for

Passive monitoring platforms, fall prevention systems, medication management tools, functional assessment technologies, and care partner communication solutions whose primary value proposition is preventing high-cost acute events rather than generating billable clinical data. PACE is also a strong early-market channel for companies that do not yet have the clinical evidence required for SSBCI or ACCESS participation but can demonstrate feasibility and usability in a controlled, high-need population.

KEY ELIGIBILITY CRITERIA

  • No CMS enrollment or certification required from the developer. PACE organizations contract independently.

  • D-SNPs require plan-specific contracting and follow the same annual Medicare Advantage bid cycle as other MA plans.

REGULATORY AND EVIDENCE REQUIREMENT

  • Cost-avoidance evidence like avoided hospitalizations, ED visits, or reduced in-person aide hours is more persuasive than clinical trial data in this context.

  • Functional outcome evidence (ADL/IADL maintenance, care partner burden reduction measured by Zarit Burden Interview (ZBI).) is preferred for PACE IDT teams.

  • No FDA device definition required unless making a clinical claim.

PRIMARY FAILURE POINTS

  • Approaching PACE with an RPM billing pitch rather than a cost-avoidance pitch.

  • Underestimating the implementation complexity of the PACE population: high functional impairment, low digital literacy, and heavy care partner dependency mean that a product performing adequately in a healthier older adult cohort may require significant adaptation before it works here.

Medicaid HCBS waivers

✓ Billable today (state-dependent)

State Medicaid Home and Community-Based Services (HCBS) waivers fund community-based alternatives to institutional care for Medicaid beneficiaries. Some states have established explicit “Remote Supports” or technology-assistance categories within their waivers. Colorado, for example, offers Remote Supports through its Community First Choice benefit.  This is not a federal pathway: eligibility, rates, and approved service categories vary state by state and are gated by waiver renewal cycles.

How developers get paid

Developers must enroll as an approved provider within the target state’s Medicaid waiver program and receive referrals through the state’s case management agency infrastructure. Services are authorized by the case management agency; enrolled providers then bill the state Medicaid program.. This means developer revenue depends on building referral relationships with county-level case managers and area agencies on aging, not on direct contracting with the state Medicaid office. The pathway rewards developers willing to invest in local partnership infrastructure.

Best fit for

Smart home sensors, passive safety monitoring systems, medication management devices, and remote support platforms that can substitute for or reduce in-person aide hours for Medicaid-eligible older adults. Particularly well-suited for developers willing to prioritize a single state deeply rather than pursuing national scale immediately, since the state-by-state nature of this pathway rewards geographic focus. Federally qualified health centers (FQHCs), area agencies on aging (AAAs), and home health agencies are natural distribution partners.

KEY ELIGIBILITY CRITERIA

  • The state’s waiver must already define a relevant technology service category.

  • Developers must enroll as an approved provider and build referral relationships with county and local case management agencies.

REGULATORY AND EVIDENCE REQUIREMENT

  • Varies by state. Prior approval is generally required before services are reimbursed, administered through a case management agency.
  • No FDA device requirement.

PRIMARY FAILURE POINTS

  • Assuming this is a federal, uniform pathway. A category that exists in one state may not exist in the next.

  • Waivers operate on 3-5 year renewal cycles, which can constrain when a new category can even be proposed.

Sources: Colorado Dept. of Health Care Policy and Financing, “Remote Supports“; Medicaid.gov, “Application for a §1915(c) HCBS Waiver”; MACPAC, “Rate-Setting for Medicaid HCBS” (Aug. 2025).

Direct-to-Consumer (Cash-Pay)

✓ Billable today (no gate)

The older adult or family care partner pays directly – no insurance or institutional approval involved. This is the fastest pathway to initial revenue on this list and the one with the lowest evidentiary bar, but it is also the most capital-intensive to scale, where getting new customers gets expensive fast, and where the most common misunderstandings of who the actual buyer is emerge.

How developers get paid

Direct transactions from subscription fees, one-time device purchases, or monthly service fees paid by the older adult or, more commonly, by an adult child acting as the purchasing decision-maker. You get paid instantly once a customer converts, but building a repeatable acquisition channel to reach older adults or their adult children at scale requires significant upfront marketing investment and a longer runway than individual sales cycles suggest.

Best fit for

Consumer-grade safety and independence products like personal emergency response devices, voice assistant integrations, home sensor systems, family communication platforms, and medication reminder tools. Consumer-grade safety and independence products like personal emergency response devices, voice assistant integrations, home sensor systems, family communication platforms, and medication reminder tools. 

KEY ELIGIBILITY CRITERIA

  • None formally. Practically, the purchaser’s willingness and ability to pay (often an adult child, not the older adult) is the qualifying factor.

  • This is the fastest pathway to market.

REGULATORY AND EVIDENCE REQUIREMENT

  • No regulatory evidence requirement. Usability, trust, and word-of-mouth/referral credibility drive conversion.

PRIMARY FAILURE POINTS

  • Assuming the purchaser and the user are the same person.

  • Underestimating customer acquisition costs and the time needed to build a repeatable, trusted acquisition channel. Fast individual sales cycles can mask a slow-to-build channel underneath.

Next step

Explore strategies for integrating your AgeTech product into care ecosystems.

Go to ecosystem integration