Did you know that Centers for Medicare and Medicaid has finalized new policies for remote patient
monitoring which is reimbursed under Medicare program? These changes include part of Physician Fee
Schedule Final Rule that’s intended to clarify CMS position about how it interprets the necessities
and requirements for remote patient monitoring services.
As discussed in the earlier topics, Remote Patient Monitoring refers to the collection and analysis
of patient physiologic data which is used to develop treatment plans related to health conditions or
chronic diseases. Five primary Medicare remote patient monitoring CPT codes are 99091, 99453, 99454,
99457, and 99458.
Top 10 Remote Patient Monitoring FAQs are based on CMS policies Final Rule 2021.
1.Should patient have chronic disease condition to qualify Remote Patient Monitoring?
Not necessarily be! Back in 2019, CMS had described remote patient monitoring services as services
provided to patients with chronic conditions. But 2021 Final Rule confirms that healthcare
professionals may furnish remote patient monitoring services in order to remotely collect and
analyze physiological data or information from those patients with acute health conditions
accompanied by patients with chronic conditions.
2.Can Remote Patient Monitoring be used with both New and Established Patients?
Actually, 2021 Final Rule from CMS states that remote patient monitoring services are very limited
to established patients compared to that of new patients.
Supporting this statement, CMS declared that any healthcare professional who has an established
relationship with patient will likely be given an opportunity to render New patient E/M services.
During New patient E/M services, healthcare professional must collect relevant patient history and
reports of conducted physical exam appropriately.
Simultaneously, healthcare professionals would be provided information that’s necessary or required
to understand present medical status of patients before preferring remote patient monitoring
services and developing treatment plans.
CMS had waived off established patient restrictions at the time of Public Health Emergency but in
2021 Final Rule, CMS has declined to extend waiver beyond Public Health Emergency.
CMS waiver suggests healthcare professionals to render remote patient monitoring services without
conducting initial New Patient E/M services.
Later when Public Health Emergency expires, it’s required to maintain as established patient-
practitioner bonding or relationship to bill Medicare services with CPT codes, 99453, 99454, 99457,
and 99458.The following will require healthcare professionals to conduct New Patient E/M services
CMS is yet to issue public guidance on healthcare professionals using telehealth in order to conduct
new patient E/M services before enrolling a beneficiary when it comes to remote patient monitoring
program.
However, it’s noted that CMS allows the use of real time interactive audio and video technology just
to satisfy interaction element of E/M services for Medicare telehealth services.
Healthcare professionals must also know that new patient E/M service codes are listed among Medicare
covered telemedicine services.
3.Who can Order and bill Remote Patient Monitoring services?
Remote Patient Monitoring codes are considered as Evaluation and Management Services by allowing
healthcare professionals to bill remote patient monitoring services.
Final Rule 2021 has confirmed that remote patient monitoring can be ordered as well as billed by
only physicians or non-physicians eligible for medical billing Medicare E/M services.
4.Who can Furnish Remote Patient Monitoring Services and Obtain Consent?
When the CPT code 99091 only can be furnished by qualified healthcare professionals, CPT codes 99457
and 99458 can be furnished by a particular healthcare professional, staff or any other physician.
While referring to particular service described by a CPT code for Medicare purposes, a physician or
other qualified healthcare professional is an individual whose scope of practice and Medicare
benefit category includes the service and who is authorized to independently bill Medicare for the
service.
Consent to RPM is obtained only when RPM services are furnished. The consent can be obtained by
individuals under contract with the billing healthcare professionals or qualified healthcare
professional.
5.Interactive Communication with Patients means what?
In 2021, CMS had issued correction by clarifying its originality in the 2021 Physician Fee Schedule
Final Rule.
The correction states that the 20-minutes of intra-service work associated and connected with CPT
codes 99457 and 99458 includes a healthcare professional’s time engaged in “interactive
communication” and also time engaged in non-face-to-face care management services during the entire
month.
The time in the descriptor for these codes 99457 and 99458 includes for all elements of the work
related to remote physiologic monitoring for example, review, analysis, interpretation, development
of treatment plan and treatment management involving patient communication that’s not meant to be
limited to synchronous time spent communicating with the patient regarding their treatment plan.
6.What did the Fact Sheet issued by CMS state?
It stated, “We clarified that for CPT codes 99457 and 99458, an “interactive communication” is a
conversation that occurs in real-time and includes synchronous, two-way interactions that can be
enhanced with video or other kinds of data as described by HCPCS code G2012. We further clarified
that the 20-minutes of time required to bill for the services of CPT codes 99457 and 99458 can
include time for furnishing care management services as well as for the required interactive
communication”.
7.What type of Remote Patient Monitoring services qualify for Medicare Services?
Remote patient monitoring devices must encounter Food and Drug Association’s definition of medical
device as mentioned in section 201(h) of the Federal, Food, Drug and Cosmetic Act.
CMS had already confirmed language is not added in the CPT Codebook indicating the remote patient
monitoring device which must be FDA-cleared and registered, but such clearance may be appropriate.
The remote patient monitoring device must digitally and automatically upload patient physiologic
data and data cannot be self-recorded or self-reported by the patient.
8.How many days should RPM monitors and report data in a month?
Even when multiple medical devices are provided to a patient, the services associated or involved
with all the medical devices can be billed only by one healthcare professional, only once per
patient, in every 30 days, and only when at least 16 days of data is being collected.
9.What are those Remote Patient Monitoring codes considered to be expense only?
CMS began with two practice expense only codes 99453 and 99454. These codes are supposed to cover
clinical staff timings, supplies and equipment, medical device used for typical case of remote
monitoring.
The CPT code 99453 reflects clinical staff time that includes instructing a patient about using one
or more medical devices.
CPT code 99454 includes the medical device or devices provided to the patient and the programming of
the medical device for repeated monitoring.
10.What are Remote Patient Monitoring and Management Codes?
Remote Patient Monitoring codes are not limited to just CPT codes 99091, 99453, 9454, 94557, and
99458. There are additional and more specific codes available for billing that allows remote
monitoring for example, CPT code 95250 for continuous glucose monitoring and CPT codes 99473 and
99474 for self-measured blood pressure monitoring.
CMS Clarifies Reimbursement for Remote Patient Monitoring
The Centers for Medicare and Medicaid Services has made certain updates to 2021 physician fee
schedule by also allowing to improve reimbursement rates for remote patient monitoring.
Earlier, in a final rule to qualify for reimbursement under CPT codes 99457 and 99458 CMS has
mandated minimum 20 minutes of interactive communication time between healthcare provider and
patient over a month, but it couldn’t be part of the 20 minutes of RPM care.
CMS has clarified now that interactive communication time between healthcare provider and patient
can be included in person and connected health channels.
It drew attention to that week’s corrections and criticized the initial guidelines when they were
released in a preliminary draft last year.
It’s the first time CMS provided published guidance on the interactive communication requirement in
the context of Remote Patient Monitoring.
More significantly, it provides healthcare professionals a pathway in developing protocols for data
collection and communicating with patients through an RPM platform.