We're back with our most-anticipated webinar of the year! If you are interested in leveraging the new RTM codes or learning more about expanded CCM and PCM reimbursement opportunities in the 2022 MPFS, join us on January 19th!
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On November 2, 2021, the Centers for Medicare and Medicaid Services (“CMS”) finalized the Medicare Physician Fee Schedule for Calendar Year 2022 (the “Final 2022 MPFS” or the “Final Rule”). As we noted in our July article discussing the Proposed 2022 MPFS, CMS made some significant proposed changes to allow for audio-only telehealth in some limited circumstances. In addition, the agency also proposed to enable remote “direct supervision,” which would allow practitioners to supervise clinical staff billing incident to their services as long as they could be available by audio/video communication as necessary.
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In the Final Medicare Physician Fee Schedule (“MPFS”) for 2022 (the “Final Rule”) issued on November 2, 2021, the Centers for Medicare and Medicaid Services (“CMS”) added five new CPT codes in the categories of Chronic Care Management (“CCM”) and Principal Care Management (“PCM”) and increased reimbursement for already existing codes in the same categories. Despite stakeholder feedback, CMS refrained from making any changes to the existing rules for obtaining beneficiary consent for CCM and PCM.
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This article examines the new CPT codes for Remote Therapeutic Monitoring as finalized for reimbursement in the 2022 Medicare Physician Fee Schedule, discussing key takeaways and implications for digital health and remote patient monitoring companies.
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This is our take on the approach CMS should follow in improving and finalizing the RTM codes and associated reimbursement that improve patient outcomes and lower the overall cost of care. It is based on our extensive work with remote patient monitoring and care management digital health companies along with the physician practices who use the existing care management codes – including Remote Patient Monitoring (“RPM”), Chronic Care Management, Principal Care Management, and Behavioral Health Integration.
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On July 13th, the Centers for Medicare and Medicaid Services (“CMS”) released its proposed Medicare Physician Fee Schedule for Calendar Year 2022 (the “2022 Proposed MPFS” or the “Proposed Rule”). In doing so, it recognized five new CPT codes for Remote Therapeutic Monitoring (“RTM”) of “non-physiologic” patient data such as “musculoskeletal system status, respiratory system status, therapy (medication) adherence, and therapy (medication) response” as well as pain. While this new code set is welcomed by advocates for virtual care, the 2022 Proposed MPFS that discusses RTM may raise just as many questions as it answers.
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