CMS Finalizes Changes to Remote Patient Monitoring in the 2020 Medicare Physician Fee Schedule
Nov. 3, 2021 UPDATE: The Final 2022 MPFS has arrived! Check out our latest post on New Reimbursement for Remote Patient Monitoring
August Update: Read about the 2021 Proposed Medicare Physician Fee Schedule in our post summarizing proposed changes to Digital Health and Remote Patient Monitoring and our post about changes to Telehealth.
Update: Head to our resource page “Responding to COVID-19: Resources for Telehealth and Remote Patient Monitoring”
The Centers for Medicare and Medicaid Services (CMS) released the Final Medicare Physician Fee Schedule for CY 2020 (the “2020 MPFS”) on November 1, 2019, finalizing some important changes relating to Remote Patient Monitoring (RPM) services, but leaving many questions unanswered as of yet.
Additional Reimbursed Time for Remote Patient Monitoring
As a reminder, CPT Code 99457 as currently written is billable after “20 minutes or more of clinical staff/physician/other qualified professional time with a patient in a calendar month.” In response to feedback from stakeholders that reimbursement for additional time spent monitoring a particular patient was warranted, CMS proposed and has now finalized a new code, CPT Code 99458, for additional 20 minutes of time spent monitoring a patient during a calendar month.
This is good news for practitioners who are implementing RPM services for more complex patients who may very well require significantly more time in managing their treatment. Even better news is CMS’ decision to value CPT Code 99458 at 0.61 RVU, the same valuation finalized for CPT Code 99457. In its proposed rule, CMS had rejected the RUC’s recommended valuation of 0.61 RVU for CPT Code 99458, setting it instead at 0.50 RVU. In their comments, stakeholders argued that the valuations should be the same for both codes, as there were no efficiencies to be gained during the additional 20 minutes of time.
The final code descriptors for these RPM codes are as follows:
CPT code 99457: Remote physiologic monitoring treatment management services, clinical staff/physician/other qualified health care professional time in a calendar month requiring interactive communication with the patient/caregiver during the month; initial 20 minutes
CPT code 99458: Remote physiologic monitoring treatment management services, clinical staff/physician/other qualified health care professional time in a calendar month requiring interactive communication with the patient/caregiver during the month; additional 20 minutes
Remote Patient Monitoring as a Designated Care Management Service under General Supervision
In the final 2020 MPFS, CMS rightly notes that Remote Patient Monitoring services involve “establishing, implementing, revising, and monitoring a specific treatment plan for a patient,” as do all Designated Care Management Services. 42 CFR Section 410.26(b)(5) is clear that these services can be provided by clinical staff and billed “incident to” a billing practitioner’s services under “general supervision” of a practitioner – meaning that the clinical staff need not be present in the same physical location as the billing practitioner.
In finalizing RPM as a Designated Care Management Service, CMS goes on to explicitly state that RPM services may be provided by clinical staff under the general supervision of a billing practitioner, and accordingly billed incident to the supervising practitioner’s services. This means that vendors of Remote Patient Monitoring may provide their customers with the option of a completely outsourced package of services, where clinical staff contracted or employed by the vendor may monitor patient data from an off-site location and escalate potential issues to be addressed by the patient’s practice.
Future Rulemaking relating to Remote Patient Monitoring
In the final 2020 MPFS, CMS noted that many commenters raised concerns regarding ambiguities in the RPM code descriptors and unanswered questions around proper implementation of RPM services. Questions raised by commenters in response to the Proposed Rule included, as examples:
• What specifically is meant by “physiologic parameters?”
• What is “digitally transmitted data,” as opposed to “patient-reported data?”
• What types of devices are a “medical device” for purposes of RPM?
• What constitutes “interactive communication” in the view of CMS?
• Who, exactly, can furnish and bill for RPM services?
• What type of documentation is needed to bill for RPM?
• Can the RPM codes be used for patients without chronic conditions?
While CMS stated that they understand the frustration of commenters around these ambiguities, they punted on specific answers to these and other questions relating to use of the Remote Patient Monitoring codes.
Remote Patient Monitoring in RHCs and FQHCs
CMS acknowledged comments requesting clarification on whether Rural Health Clinics and Federally Qualified Health Centers can be reimbursed for RPM services and responded that “services such as RPM are not separately billable because they are already included in the RHC All Inclusive Rate (AIR) and FQHC Prospective Payment System (PPS) payment.” This response seems incongruous with CMS’ position that Care Management Services are billable, and will hopefully be re-examined in any future rulemaking.
Single Advance Beneficiary Consent for Communication Technology Based Services and Interprofessional Internet Consultations
CMS also shifted its position on advance beneficiary consent for each of certain services such as Virtual Check-Ins under HCPCS G2012, Remote Evaluation of Images under HCPCS G2010, and the Interprofessional Internet Consultation codes 99446, 99447, 99448, 99449, 99451, and 99452. Under the final 2020 MPFS, practitioners can contain a single consent annually from patients utilizing Communication Technology Based Services and/or Interprofessional Internet Consultations, thereby easing the administrative burden on practitioners providing those services.
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