{"id":7338,"date":"2019-08-06T10:08:47","date_gmt":"2019-08-06T10:08:47","guid":{"rendered":"http:\/\/tele.healthcare\/?p=7338"},"modified":"2019-08-06T10:08:47","modified_gmt":"2019-08-06T10:08:47","slug":"remote-patient-monitoring-medicare-proposes-two-major-expansions","status":"publish","type":"post","link":"https:\/\/drmiltie.com\/at-home-testing\/remote-patient-monitoring-medicare-proposes-two-major-expansions\/","title":{"rendered":"Remote Patient Monitoring: Medicare Proposes Two Major Expansions"},"content":{"rendered":"\n

Tuesday, August 6, 2019\n\n\n\n\n\n\n\n<\/p>\n\n\n\n

Last week, CMS proposed two significant changes to remote patient monitoring (RPM) services reimbursed under the Medicare program. The changes, part of the proposed 2020 Physician Fee Schedule<\/a>, have been hotly anticipated by digital health providers hoping to see more clarity and flexibility for RPM services.<\/p>\n\n\n\n

The creation of new RPM codes<\/a> at the beginning of 2019 (CPT Codes 99457, 99454, and 99453) was a big step forward to expanding patient digital health and improve health care delivery, outcomes, and cost management. Questions remained on how to properly use and bill the new RPM codes, and what business and staffing models are required by Medicare. Providers asked if RPM must be billed incident to a professional\u2019s services under direct supervision<\/a>, or if they could use general supervision similar to Chronic Care Management (CCM) services? What types of RPM devices are covered under the practice expense codes of CPT Codes 99454 and 99453? May patients manually enter data into a RPM device? And why is CPT Code 99454 billed on 30 day cycle while CPT Code 99457 is billed on a monthly basis? While CMS did not address all of these questions in the proposed Physician Fee Schedule rule, it did offer some helpful clarity and propose expanding Medicare RPM services in two significant ways: 1) allowing RPM to be delivered under general supervision; and 2) creating a new add-on code for patients who receive more than 20 minutes per month of RPM services.<\/p>\n\n\n\n

RPM Can Be Delivered Under General Supervision<\/h3>\n\n\n\n

This is arguably the single most important and beneficial change for digital health in the entire proposed 2020 Physician Fee Schedule. When CMS first created the RPM codes, they stated RPM could not be delivered incident to, reasoning<\/a> that CPT code 99457 describes professional time and \u201ctherefore cannot be furnished by auxiliary personnel incident to a practitioner\u2019s professional services.\u201d  An incident to service is one that is performed under the supervision of a physician (broadly defined), and billed to Medicare in the name of the physician, subject to certain requirements. Subsequently, CMS issued a technical correction<\/a> allowing incident to billing of RPM services by auxiliary personnel under direct supervision. Direct supervision means the physician and auxiliary personnel must be in the same building at the same time (albeit not the same room). General supervision, in contrast, does not require the physician and auxiliary personnel to be in the same building at the same time, and the physician could instead use telemedicine to exert general supervision over the auxiliary personnel.<\/p>\n\n\n\n

Industry insiders advocated for changing the RPM rules to expressly allow incident to billing of RPM under general supervision and CMS concurred. Under the proposed rule, RPM services reported with CPT codes 99457 and 994X0 may now be furnished under general supervision rather than the currently required direct supervision. The physician or other qualified healthcare professional supervising the auxiliary personnel need not be the same individual treating the patient more broadly.  However, only the supervising physician or other qualified health care professional may bill Medicare for the incident to services. <\/p>\n\n\n\n

Changing the RPM rules to expressly allow incident to billing of CPT code 99457 under general supervision greatly expands the potential operations and business models associated with RPM services, thereby allowing more patients to enjoy the quality-improving benefits of remote patient monitoring.<\/p>\n\n\n\n

New RPM Code for Extra Minutes<\/h3>\n\n\n\n

CMS has also proposed changing CPT code 99457 to only cover the initial <\/em>20 minutes of monitoring services, while a new CPT code 994X0 would be used as an add-on code for those patients who receive additional 20 minutes intervals of RPM. CMS did not address how often the new add-on code 994X0 can be billed per month, or if there is a maximum limit. CMS has proposed a work RVU of 0.50 and direct PE inputs for the new add-on code. The proposed code descriptions are as follows:<\/p>\n\n\n\n