CMS Proposes Changes to and Reaffirms Remote Monitoring Services

The Facilities for Medicare & Medicaid Service (CMS) has included quite a few proposed modifications and additions to distant monitoring and care administration in its 2024 doctor charge schedule (PFS) proposed rule. We explored the important thing modifications and different essential takeaways suppliers should learn about from the proposed rule in a particular webinar on July 25 (watch the on-demand recording).

Within the proposed rule, CMS has taken an attention-grabbing place regarding distant monitoring providers — extra particularly, distant physiologic monitoring (i.e., distant affected person monitoring or RPM) and distant therapeutic monitoring (RTM). The company has included a couple of proposed modifications. That is typical for a proposed rule.

What’s atypical is CMS summarizing a few of the present guidelines for distant monitoring providers. The choice by CMS to allocate a portion of the proposed rule to resharing this data was led to following the submission of many questions regarding correct RPM and RTM coding and billing necessities, notes CMS within the proposed rule.

Learn on to rise up to hurry on the distant monitoring providers points lined on this newest proposed rule.

Two Code Households: RPM and RTM

CMS reiterated that it has established funds for 2 outlined CPT code households describing several types of distant monitoring providers: distant physiologic monitoring (RPM) and distant remedy monitoring (RTM). Observe: We offer the lists of codes close to the tip of this submit.

Reaffirmations of Present Guidelines:

Normal Supervision Guidelines Apply

CMS reiterated that it has designated the above distant monitoring codes as care administration providers, that means its guidelines for basic supervision apply. “Normal supervision,” as defined by Medicare, means a service is delivered or furnished underneath a doctor’s total route and management however the service doesn’t essentially require the doctor’s bodily presence throughout the supply of service.

Concurrent Billing

CMS reiterated that RTM or RPM providers might be billed concurrently with persistent care administration (CCM), transitional care administration (TCM), principal care administration (PCM), chronic pain management (CPM), or behavioral well being integration (BHI).

Nevertheless, practitioners could invoice RPM or RTM, however not each RPM and RTM, concurrently with the aforementioned providers.

New Vs. Established Sufferers

Throughout the COVID-19 public well being emergency (PHE), CMS eliminated the requirement that there should be a longtime patient-practitioner relationship to provoke the supply of distant affected person monitoring providers. Within the 2024 proposed rule, CMS reiterated that with the tip of the PHE, RPM providers should as soon as once more solely be furnished to established sufferers. Established sufferers embrace those that obtained preliminary distant monitoring providers throughout the PHE.

16-Day RPM Requirement

Previous to COVID-19, the variety of measurement days in a month (i.e., 30 days) required to invoice distant monitoring providers was simple. The minimal quantity was 16. However a federal waiver issued early within the pandemic added a caveat to this requirement when CMS acknowledged it was allowing suppliers to ship and invoice for RPM providers to sufferers with suspected or confirmed instances of COVID-19. The waiver acknowledged that throughout the PHE, CMS would allow reporting of RPM providers to Medicare for durations of time of fewer than 16 days however at least two days. This short-term rule change was generally known as Medicare’s “2-day RPM requirement.”

What’s essential to grasp is billing for CPT codes 99453 and 99454 requires utilization of a tool that collects and transmits 16 or extra days of information each 30 days for the billing of those codes — i.e., the “16-day RPM requirement.” 

Some suppliers and RPM service distributors incorrectly (and one may argue inappropriately, in some cases) utilized the 2-day RPM requirement to all sufferers throughout the PHE. In early 2021, CMS acknowledged its 2-day RPM requirement ought to solely be utilized to sufferers with a suspected or confirmed prognosis of COVID-19.

Within the 2024 proposed rule, CMS reiterated that with the tip of the PHE got here the tip of the usage of the 2-day necessities for sufferers with a suspected or confirmed prognosis of COVID-19. The 16-day requirement is as soon as once more the requirement for billing distant monitoring providers for all sufferers — extra particularly, CPT codes 98976, 98977, 98978, 98980, and 98981.

Single Practitioner Billing

Within the new proposed rule, CMS reiterated that solely a single practitioner can invoice RPM CPT codes 99453 and 99454, or RTM CPT codes 98976, 98977, 98980, and 98981, throughout a 30-day interval (and solely when no less than 16 days of information have been collected on no less than one medical gadget).

A number of Medical Units

CMS reiterated that even when sufferers are supplied and utilizing a number of medical gadgets, the providers related to all these medical gadgets can solely be billed as soon as per affected person per 30-day interval.

Proposed 2024 Rule Modifications:

Clarifying Concurrent RPM and RTM Billing

Within the 2024 proposed rule, CMS is proposing to make clear that RPM and RTM could not be billed collectively and no time ought to be counted twice by billing for concurrent RPM and RTM providers.

In cases when a affected person receives each RPM and RTM providers and there could also be a number of gadgets used for monitoring, CMS notes that its current guidelines would apply on this scenario: providers (which should be cheap and crucial) related to all medical gadgets can solely be billed by one practitioner; solely as soon as per affected person, per 30-day interval; and solely when no less than 16 days of information have been collected.

Distant Monitoring Throughout International Durations for Surgical procedure

CMS can also be proposing to make clear guidelines regarding the usage of distant monitoring throughout world durations for surgical procedure. In circumstances the place a beneficiary undergoes a process or surgical procedure (and receives associated providers) lined underneath a world interval cost, CMS is proposing to make clear that distant physiologic monitoring providers or distant therapeutic monitoring providers — however not each RPM and RTM providers concurrently — could also be furnished individually to the beneficiary. The practitioner would obtain cost for the RTM or RPM providers, separate from the worldwide service cost, so long as different necessities for the worldwide service and some other service throughout the world interval are met.

For these beneficiaries receiving providers throughout a world interval, a supplier could furnish RPM or RTM providers — however not each — to the person beneficiary and the practitioner would obtain separate cost, so long as the distant monitoring providers are unrelated to the prognosis for which the worldwide process is carried out and so long as the aim of the distant monitoring addresses an episode of care separate and distinct from the episode of take care of the worldwide process. In different phrases, distant monitoring providers supplied are supposed to deal with an underlying situation not linked to the worldwide process or service.

Key Takeaways From the 2024 PFS Proposed Rule

In case you are all for studying extra about these proposed modifications to distant monitoring providers, together with how they’d have an effect on suppliers if finalized, and different noteworthy, proposed modifications to distant care administration included within the 2024 PFS proposed rule, do not miss our upcoming, particular webinar on July 25 at 2:00 EDT. Learn more and register here.

RPM and RTM CPT Codes

Distant physiologic/affected person monitoring

• 99453 — Distant monitoring of physiologic parameter(s) (eg, weight, blood strain, pulse oximetry, respiratory movement charge), preliminary; set-up and affected person training on use of apparatus
• 99454 — Distant monitoring of physiologic parameter(s) (eg, weight, blood strain, pulse oximetry, respiratory movement charge), preliminary; gadget(s) provide with every day recording(s) or programmed alert(s) transmission, every 30 days
• 99457 — Distant physiologic monitoring remedy administration providers, medical workers/doctor/different certified well being care skilled time in a calendar month requiring interactive communication with the affected person/caregiver throughout the month; first 20 minutes)
• 99458 — Distant physiologic monitoring remedy administration providers, medical workers/doctor/different certified well being care skilled time in a calendar month requiring interactive communication with the affected person/caregiver throughout the month; every further 20 minutes (Listing individually along with code for main process

Distant therapeutic monitoring

• 98975 — Distant therapeutic monitoring (eg, remedy adherence, remedy response); preliminary set-up and affected person training on use of apparatus
• 98976 — Distant therapeutic monitoring (eg, remedy adherence, remedy response); gadget(s) provide with scheduled (eg, every day) recording(s) and/or programmed alert(s) transmission to observe respiratory system, every 30 days
• 98977 — Distant therapeutic monitoring (eg, remedy adherence, remedy response); gadget(s) provide with scheduled (eg, every day) recording(s) and/or programmed alert(s) transmission to observe musculoskeletal system, every 30 days
• 98978 — Distant therapeutic monitoring (eg, remedy adherence, remedy response); gadget(s) provide with scheduled (eg, every day) recording(s) and/or programmed alert(s) transmission to observe cognitive behavioral remedy, every 30 days
• 98980 — Distant therapeutic monitoring remedy administration providers, doctor or different certified well being care skilled time in a calendar month requiring no less than one interactive communication with the affected person or caregiver throughout the calendar month; first 20 minutes
• 98981 — Distant therapeutic monitoring remedy administration providers, doctor or different certified well being care skilled time in a calendar month requiring no less than one interactive communication with the affected person or caregiver throughout the calendar month; every further 20 minutes (Listing individually along with code for main process)

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