The Centers for Medicare and Medicaid Services (CMS) have released the Final Medicare Physician Fee Schedule (MPFS) for 2021. Along with clarifying portions of the proposed rule, the 2021 MPFS renders some of the changes during the public health emergency (PHE) permanent and allows others to expire at the end of the PHE. Below, we break down important components of the final rule related to remote patient monitoring (RPM). You can find an overview of the CPT codes for RPM, in our previous post.
Patient Consent, Education, and Setup of RPM
During COVID-19, CMS has permitted patients to consent to receive RPM services when those services are furnished rather than ahead of services being provided. This change is made permanent by MPFS 2021 and will continue beyond the end of the PHE.
Additionally, CMS permanently established that auxiliary personnel (including clinical staff and contracted employees) may provide patient education on RPM, as well as RPM device setup. With this policy, RPM365 continues to offer a turnkey service that encompasses completion of the patient education and device setup described under CPT codes 99453 and 99454.
CMS has allowed HCPs to order RPM services for new patients during the PHE, and that will expire at the end of the PHE. However, the 2021 MPFS clarifies that an HCP may establish a relationship with a patient through another E/M service prior to ordering RPM and this does not explicitly require an in-person visit.
Patient Use of RPM and Data Transmission
In an important clarification from the proposed rule, CMS has stated that the 20 minutes of time needed to bill CPT codes 99457 and 99458 can include “time for furnishing care management services, as well as for the required interactive communication.” Interactive communication (defined as “at a minimum, a real-time synchronous, two-way audio interaction that is capable of being enhanced with video or other kinds of data transmission”) remains a requirement for billing these CPT codes.
CMS also requires that RPM data can be transmitted to the HCP from a “connected” device (Bluetooth, wi-fi, or cellular devices, for example) rather than keyed in by the patient. Many have expressed the need for additional information to give context for the RPM readings. Comments on the proposed rule included feedback that self-reported information like pain and mood can be helpful in assessing patient health and managing their care. RPM365 accomplishes this by allowing a space for the patient to enter notes alongside data transmissions so that HCPs can see a holistic picture of patient health while fulfilling the requirements for reimbursement.
Finally, CMS will only require two days of data collection and transmission each 30 days to bill CPT codes 99453 and 99454 until the end of the PHE, at which point the previous threshold of 16 or more days of RPM data collection and transmission within a 30-day period will be reinstated. Some have argued that 16 days of readings are unnecessary or even detrimental to the patient for certain conditions, but this remains unaltered in the 2021 MPFS. However, Nixon Gwilt Law reports, “Notably the Final 2021 MPFS does not appear to prohibit billing CPT codes 99457 and 99458 when 20 minutes of care management services time has accrued during a calendar month, regardless of whether or not 16 days of transmissions have occurred during that time.”
Continued Restrictions on Use of RPM
Multiple policies remain in place that limit the ability to bill for RPM. CMS continued its policy of not allowing reimbursement for RPM services separate from Principle Care Management for Rural Health Clinics and Federally Qualified Health Centers. The final rule also did not extend the ability to bill for RPM services for physical, occupational, or behavioral therapy. As before, RPM services can only be ordered and billed by physicians, nurse practitioners, or physician assistants who can provide E/M services.
Have questions about these changes to RPM reimbursement? Contact us to learn more.