Earlier this year, in a first-of-its-kind move, CMS made remote patient monitoring (RPM) a separately-reimbursable service under Medicare. Now, CMS has proposed three new codes for RPM services, retitled “Chronic Care Remote Physiologic Monitoring,” which do a far better job reflecting how providers can more effectively and efficiently use RPM technology to monitor and manage patient care needs, including chronic care management. If finalized, these three codes would go live January 1, 2019. Until then, CMS is accepting comments on the proposed codes through September 10, 2018.
Medicare already offers separate reimbursement for RPM services billed under CPT code 99091. That service is defined as the “collection and interpretation of physiologic data (e.g., ECG, blood pressure, glucose monitoring) digitally stored and/or transmitted by the patient and/or caregiver to the physician or other qualified health care professional, qualified by education, training, licensure/regulation (when applicable) requiring a minimum of 30 minutes of time.” It went live for the first time earlier this year (effective January, 2018).
While industry advocates generally applauded CMS for activating RPM reimbursement, they simultaneously recognized CPT 99091 fails to optimally describe how RPM services are furnished using current technology and staffing models. This failure may be due to the fact that CPT 99091 is 16 years old and had never before been a separately payable service. (It is an older code CMS “unbundled” and designated as a separately-payable service.) Indeed, the AMA’s CPT Editorial Panel developed and finalized a set of three new RPM codes in late 2017. These codes (CPT 990X0, 990X1, and 994X9) are what CMS recently proposed activating effective in 2019. The new codes do a far better job accurately reflecting contemporary RPM services.
The new Chronic Care Remote Physiologic Monitoring codes are:
The three biggest changes between from the new Chronic Care Remote Physiologic Monitoring codes and the current CPT 99091 are as follows:
What CMS did not mention in the proposed rule is whether or not CPT 994X9 can be delivered via “incident to” billing under the general supervision of the billing physician. The default rule is that “incident to” billing must be performed under direct supervision (meaning the physician must be present in the office suite and immediately available to provide assistance and direction throughout the time the auxiliary personnel is performing services). However, CMS is allowed to make exceptions, which it did for Chronic Care Management (CCM) services.
Like CCM, most RPM services are most efficiently delivered under general supervision, which does not require the physician and auxiliary personnel to be in the same building at the same time, and the physician could instead exert general supervision via telemedicine. This makes a huge difference in operations and business models, but in order for these new RPM codes to work in the real world, it is near-essential that CMS allow the new RPM codes to be billed “incident to” under general supervision. Ensuring CMS makes this change in connection with the final rule is very important to the success of these new codes.
Providers frustrated with the labyrinthine and narrow Medicare coverage of telehealth services can take comfort in the fact that RPM is not considered a Medicare telehealth service. Instead, like a physician interpretation of an electrocardiogram or radiological image that has been transmitted electronically, RPM services involve the interpretation of medical information without a direct interaction between the practitioner and beneficiary. As such, Medicare pays for RPM services under the same conditions as in-person physicians’ services with no additional requirements regarding permissible originating sites or use of the telehealth place of service (POS) 02 code. This means Chronic Care Remote Physiologic Monitoring does not require the use of interactive audio-video, nor must the patient be located in a rural area or a qualified originating site. Patients can even receive RPM services in their homes.
Here are four things providers and entrepreneurs interested in Chronic Care Remote Physiologic Monitoring should consider now, in order to prepare for this new opportunity:
Entrepreneurs and start-ups offering RPM technologies and services should take steps now to understand these new billing opportunities under Medicare. With the forthcoming CPT codes for Chronic Care Remote Physiologic Monitoring, this looks to be an area of significant upside potential over the coming years. In addition, hospitals and providers using RPM and non-face-to-face technologies to develop patient population health and care coordination services should take a serious look at these new codes, and keep abreast of developments that can drive recurring revenue and improve the patient care experience.
For more information on telemedicine, telehealth, virtual care, and other health innovations, including the team, publications, and other materials, visit Foley’s Telemedicine and Digital Health Industry Team and read our 2017 Telemedicine and Digital Health Executive Survey.