Partner Nate Lacktman was quoted in an mHealth Intelligence article, “CMS Clarifies 2021 PFS Reimbursements for Remote Patient Monitoring,” about amendments made to the 2021 Physician Fee Schedule to clarify reimbursement for remote patient monitoring programs.
Lacktman, chair of the firm’s national Telemedicine & Digital Health Industry team, was quoted in connection with a blog post he wrote in December about his problem with the so-called one practitioner rule. “CMS comments about RPM being billed by only one practitioner is new, and when read in context of the Final Rule, it remains unclear if CMS means a practitioner cannot bill multiple RPM services for the same patient in the same month, or if it means CMS will pay only one RPM claim per beneficiary per month,” he wrote. “If the former, a patient could enroll in different RPM programs with different specialists during the same time period (e.g., a cardiologist for the patient’s heart needs and an endocrinologist for the patient’s diabetes) and each specialist could bill Medicare for their respective RPM services. If the latter, a patient could enroll in only one practitioner’s RPM program, which is how CCM services are currently structured. CMS’ billing guidance for CCM is expressly clear about this restriction, but the RPM guidance does not use a similarly explicit statement, so there remains definite ambiguity.”