10 Key Takeaways for Remote Patient Monitoring

In 2021, the Centers for Medicare and Medicaid has released Medicare Physician Fee schedule final rule. There were few significant changes in regards to remote patient monitoring and the provision of other remote services. Few practices with the existing RPM programs or those thinking about launching programs in 2021 should take the time to understand these specific changes and ensure that their programs comply with the new rules.

This article provides 10 most significant takeaways for remote patient monitoring from the final rule.

1. Revised Definition of Interactive Communication:

  • In the final rule, the Centers for Medicare and Medicaid Services declared CPT codes 99457 and 99458 for an “interactive communication”. It is defined as a conversation occurring in real time that includes synchronous, two-way interactions that can be enhanced with video or other kinds of data.
  • Additionally, to the new definition, CMS had originally stated that it had expected all the time spent towards 99457 and 99458 to be “interactive communication”. This would most probably cause quite a commotion, as it means that activities such as text messaging, care planning and general care management would no longer be countable towards RPM billing codes.
  • Apparently, CMS readily issued accurate documentation where the agency clarified that the 20 minutes of time associated with 99457 and 99458 “should include care management services and synchronous, real-time interactions”.
  • This is clarified as the interactive communication contributes to the total time. Moreover, it is not the only activity to be included in the total time.
  • Ultimately the documentation reaffirms that some of the time for each code needs to be “interactive communication”, but it leaves the necessary proportions up in the air for future rulings.

2. Clarification Concerning Device requirements for Remote Patient Monitoring:

  • The final rule has clarified the uncertainties that surround the types of services supplied to the patients as the part of CPT 99454.
  • Of the record, CMS has stated that such devices would encounter the definition of the medical device as per the Food, Drug and the Cosmetic Act. They also electronically collect and transmit a patient’s physiologic data rather than permit patients to self-report or self-collect data.
  • The latter is very crucial as it provides clarification of the separation between self-reported and automated remote patient monitoring data.
  • There are few platforms that self-report and automate RPM patient data. This particular ruling also makes it clear that these and other mechanisms of self-recording data are no longer acceptable.

3. Re-established patient requirement:

  • Despite the healthcare industry hurdles, CMS did finalize that it will re-implement the requirement that an established patient-physician relationship exist for the furnishing of RPM following the end of the COVID-19 public health emergency.

4. Permitted consent obtainable at time of service:

  • The Centers for Medicare and Medicaid had finalized the rule for permitting healthcare providers to obtain patient consent to receive RPM services when services are initially furnished rather than in advance.

5. Approved furnishing of services by auxiliary personnel:

  • CMS also established permanent policy that allows auxiliary personnel to furnish CPT 99453 and 99454 services under a physician’s supervision.
  • It earlier defined auxiliary personnel to mean “any individual who is acting under the supervision of a physician, regardless of whether the individual is an employee, leased employee, or independent contractor of the physician, or of the legal entity that employs or contracts with the physician”.

6. Clarification of billing for services:

  • CMS clarified that only physicians and non-physician practitioners, eligible to furnish evaluation and management services, are permitted to bill RPM services using CPT 99453, 99454, 99091, 99457, and 99458. This significant aspect of the requirements was already well understood.
  • In the accurate document or correction document, the agency had clarified its position that only a single practitioner can bill 99453 and 99454 during a 30-day period.
  • This particular clarification runs in counter to the enforcement and prior general understanding of the RPM codes. It may also warrant questioning the patient if they are already receiving RPM services from another practitioner during enrollment.

7. Expanding coverage to acute conditions:

  • CMS at first described RPM as the services rendered to the patients with the chronic conditions.
  • With the final rule, it has actually clarified that healthcare professionals might furnish RPM services to patients with acute conditions as well.

8. Re-establishing 16 measurement-days to bill:

  • CMS has confirmed that it will be maintaining the existing requirement that 16 days of data for each 30 day period must be collected and transmitted to bill CPT 99453 and 99454.
  • The 16-day requirement was confirmed despite an industry push to lower the figure with some hoping it would drop to as few as six days.

9. Clarification on the two measurement-day waiver for suspected/diagnosed COVID patients.

  • One major part of confusion is the current waiver on the 16 measurement-day rule for CPT 99454 that would allow billing with just two measurement-days when the patient is suspected to have or has been diagnosed with COVID-19.
  • The fact sheet by CMS concerning the final rule reiterated the current existence of this waiver and confirmed that it will expire once the public health emergency ends.
  • However, the fact sheet and the final rule fail to mention that this requirement or the necessity was established during the public health emergency and applies solely to patients who have a suspected or confirmed case of COVID-19.
  • These omissions could also create confusion in the industry. It can prompt several large RPM companies to inform their customers that they can bill under the two measurement-day waiver for any patient regardless of COVID-19 status.

10. Approved billing CPT 99091 concurrently with newer RPM codes:

  • Until the 2021 final rule was released, it was believed that it was not permissible to bill the old provider-specific CPT 99091 used for RPM at the same time as 99457, which went into effect in 2019.
  • CMS had noted that 99091 can be billed each 30 days whenever such complex provider management occurs without affecting the practice’s ability to bill clinical staff time via CPT 99457 each calendar month.

 Remote Patient Monitoring CPT Codes You Need to Know for 2021:

  • CPT code 99453compensates providers for any time associated with on boarding and educating a patient while a clinical staff member sets up the necessary Remote Patient Monitoring devices. With 100Plus, providers can earn $24.58 per one time patient under this code.
  • CPT Code 99454reimburses providers for supplying the said patient with a Remote Patient Monitoring device for a 30-day period. 100Plus clients can take in $990 per patient annually using this CPT code.
  • CPT Code 99457compensates for the time spent monitoring physiologic parameters (weight blood pressure, pulse oximetry, and respirator flow rate). This comes in at about 20 minutes per calendar month and can earn providers $736 per patient annually.
  • CPT Code 99458is an add-on to code 99457 that reimburses providers for each additional 20 minutes per month of interactive monitoring. This code can provide up to $1,174 per patient annually to medical providers.
  • CPT code 99091focuses on data collected within a 30-day period to be analyzed remotely by a physician or medical provider. While this CPT code is still considered valid by the CMS, the codes listed above better represent the various situations that require billing. This code cannot be billed in the same calendar month as 99457 and 99458.

Remote patient monitoring codes are indeed crucial while billing the procedures. The correct document carries more accuracy essential to process the billing. Outsourcing companies can ease the work with more efficiency and accuracy.

Remote Therapeutic Monitoring in 2022

Remote therapeutic monitoring is designed specifically for the management of patients using medical devices and collecting non-physiological data like therapy, medication adherence, and medication response. The CMS has released five specific codes for remote therapeutic monitoring purposes. As RTM makes its big debut after a series of consultations and discussions, it is important for the coding teams to take special note of it and implement them in the correct way.

Practice Expense-only Codes

Among the five codes released by the CMS, three are considered as practice expense-only codes. All three codes correspond to remote therapeutic monitoring like musculoskeletal system status, respiratory system status, therapy adherence, and therapy response. Specifications for the codes are:

  • 989X1: “Initial set-up and patient education on use of equipment”
  • 989X2: “device(s) supply with scheduled (e.g., daily) recording(s) and/or programmed alert(s) transmission to monitor respiratory system, each 30 days”
  • 989X3: “device(s) supply with scheduled (e.g., daily) recording(s) and/or programmed alert(s) transmission to monitor musculoskeletal system, each 30 days”

Professional Work Codes

The other two codes fall strictly under professional work use. These codes are concerned with the “remote therapeutic monitoring treatment management services, physician/other qualified health care professional time in a calendar month requiring at least one interactive communication with the patient/caregiver during the calendar month.”

  • 989X4: Communication with the patient or caregiver for the first 20 minutes
  • 989X5: Communication with the patient or caregiver for every additional 20 minutes

Clarity on the Use of RTP

Provider offices and healthcare organizations are still new to the definitions and use of remote therapeutic monitoring and how they are different from the usual remote patient monitoring. However, the release of the five codes by the CMS has shed some light into the matter. Healthcare professionals opine that the specific requirements for RTP are still largely undefined. With the CMS laying more stress on the matter, the upcoming proposals could provide more clarity.

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