Under the Proposed Rule, physicians and non-physician practitioners – for example, nurse practitioners (NPs) and physician assistants (PAs) – can order and bill for APCM services. Here’s what digital healthcare innovators need to know.
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Stakeholders will be glad to know that CMS continued the RTM conversation with stakeholders beyond last year’s 2022 Medicare Physician Fee Schedule Final Rule (the “2022 Rule”) and directly addressed many of our questions and concerns, including NGL’s recommendations to re-visit the overall code structure to better align RTM with Remote Physiologic Monitoring (“RPM”) and other care management services.
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The much-anticipated 2023 Medicare Physician Fee Schedule Proposed Rule from CMS has arrived! More detailed analyses from the Nixon Gwilt Law team will follow, but in the meantime, here are our top takeaways from the 2023 Proposed Rule.
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On January 13, 2022, in response to numerous legal challenges premised on the lack or abuse of executive authority.
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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.
Read More![[video] Digital Health Innovators: Does your solution qualify as Software as a Medical Device (SaMD)?](https://images.squarespace-cdn.com/content/v1/563c7acce4b028323896cb89/1630919850100-SJ68VGMR0T2FN758NSE0/SaMD+for+RPM+and+RTM_blog+image_NGL.png)
If you’re in the Remote Patient Monitoring (RPM) or Remote Therapeutic Monitoring (RTM) space, then you’ll want to understand the criteria and opportunities for qualifying as Software as a Medical Device (SaMD)
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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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Dramatic changes to the Anti-Kickback Statute and the Stark Physician Self-Referral Law regulations present an unprecedented opportunity for healthcare providers and digital health companies to create new business arrangements that align incentives around care coordination and patient engagement. Such arrangements are the foundation of the Value-Based Enterprise.
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A Final Rule published by CMS makes several important changes to the Stark Law that will be a boon for physicians eager to more closely coordinate with other providers to (1) better manage patient care and (2) to participate in the shift to value-based reimbursement.
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On December 1, 2020, the Centers for Medicare and Medicaid Services (“CMS”) released its Final Medicare Physician Fee Schedule for 2021 (the “Final 2021 MPFS”), revising payment policies for services provided to Medicare beneficiaries by medical practitioners. These policies will take effect on January 1, 2021. Read on for insights from Team NGL.
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On Monday, August 3, 2020, the Centers for Medicare & Medicaid Services (“CMS”) released the 2021 Medicare Physician Fee Schedule Proposed Rule (the “Proposed Rule”). The 2021 Proposed Rule includes a new code under the Behavioral Health Integration (“BHI”) Collaborative Care Model (“CoCM”) that, if finalized, would offer reimbursement for a shorter increment of time than had previously been available under BHI.
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Carrie Nixon, of the Nixon Law Group, said the order calls for “a strategy to improve rural health by improving the communications infrastructure in rural America,” though she notes such a strategy would have to be funded.
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Nixon Law Group’s Partner, Rebecca Gwilt, was quoted in an article appearing in Home Health News discussing the new CMS proposed rules and how the supposed expansion of telehealth leaves out home health. Home health was largely ignored in the national conversation about supporting the expansion of telehealth
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On Monday, August 3, 2020, the Centers for Medicare & Medicaid Services (“CMS”) released the 2021 Medicare Physician Fee Schedule Proposed Rule (the “2021 Proposed Rule”). In the healthcare industry, the Medicare Physician Fee Schedule or “MPFS” is arguably the most prominent force shaping the industry on an ongoing basis. Each year, CMS releases a Proposed Rule mid-summer to give stakeholders a first look at what is potentially to come for the following year. Stakeholders have an opportunity to comment on those proposals, CMS reads the comments it receives, and then based on those comments CMS updates its proposals and releases a Final Rule.
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