September 07, 2018 – The American Medical Association (AMA) updated the Current Procedural Terminology (CPT) code set in 2019 to include new codes for connected health services in an effort to encourage CMS to pay for the services.

The 2019 CPT code set contains 335 code changes that will go into effect for medical billing and coding on Jan. 1, 2019.

A number of those code changes are new codes that can be used to capture the use of connected health tools that support clinicians as they engage in population health and care coordination services, as well as other innovative care delivery services, the AMA explained.

Among those new CPT codes are three remote patient monitoring codes that represent how providers use health IT system to connect with their patients in their homes and collect data for care management and care coordination.

The 2019 CPT code set also includes two new interprofessional internet consultation codes. The new codes aim to show the increasing importance and prevalence of using non-verbal communication technology to coordinate care between a consulting and treating physician, the AMA stated.

The industry group hopes the creation of new connected health codes will prompt CMS to reimburse providers for delivering innovative, technologically advanced care.

“The AMA has urged the Centers for Medicare and Medicaid Service to adopt the new codes for remote patient monitoring and internet consulting and designate the related services for payment under federal health programs in 2019,” stated AMA President Barbara L. McAneny, MD.

“Medicare’s acceptance of the new codes would signal a landmark shift to better support physicians participating in patient population health and care coordination services that can be a significant part of a digital solution for improving the overall quality of medical care,” she added.

CMS uses a portion of CPT codes in its own medical billing and coding set, the Healthcare Common Procedure Coding System (HCPCS). But the federal agency does not use the full CPT code set for Medicare and Medicaid reimbursement.

Other important CPT code changes for 2019 include the addition and revision of codes for skin biopsy, fine needle aspiration biopsy, adaptive behavior analysis, and central nervous system assessments, including psychological and neuropsychological testing.

“The CPT code set is the foundation upon which every element of the medical community—doctors, hospitals, allied health professionals, laboratories and payers—can efficiently share accurate information about medical services,” said McAneny.

“The latest annual changes to the CPT code set reflect new technological and scientific advancements available to mainstream clinical practice, and ensure the code set can fulfill its trusted role as the health system’s common language for reporting contemporary medical procedures,” she continued.

AMA’s push to get CMS on board with remote patient monitoring, internet consulting, and other connected health services is shared by many other stakeholders. Recently, close to 50 healthcare organizations and vendors called on the federal agency to improve claims reimbursement opportunities for remote patient monitoring.

The groups specifically asked CMS Administrator Seema Verma to modify and add CPT codes to enable Medicare reimbursement for mobile health programs that collect patient-generated health data in the home.

The Healthcare Information and Management Systems Society (HIMSS) also urged CMS in 2017 to “embrace a reimbursement system that recognizes the unique characteristics of connected health that enhances the care experience for the patient, providers and caregivers.”

Getting medical billing and coding up to speed with connected health services has been a long journey. But CMS recently signaled a change in its billing and coding rules.

The proposed 2019 Medicare Physician Fee Schedule would start to reimburse clinicians for virtual care, including virtual check-ins and evaluations of patient-submitted photos. The proposal would also expand Medicare-covered telehealth services to include prolonged preventative services.

“CMS is committed to modernizing the Medicare program by leveraging technologies, such as audio/video applications or patient-facing health portals, that will help beneficiaries access high-quality services in a convenient manner,” Administrator Verma stated.

Industry experts view the proposed 2019 Medicare Physician Fee Schedule as a major shift in Medicare and Medicaid’s acceptance of telehealth and connected health services.

“CMS’ proposed rule is a landmark change allowing providers to much more meaningfully use new technologies when delivering medical care,” Nathaniel Lacktman, a partner and healthcare lawyer with Foley & Lardner LLP, recently told mHealthIntelligence.com.

“By including new payment codes for remote patient monitoring, virtual check-ins, asynchronous image and video review and peer-to-peer consultations, the proposed rule exemplifies CMS’ renewed vision and desire to bring the Medicare program into the future of clinically-valid telemedicine services,” continued Lacktman, who also chairs the firm’s Telemedicine Industry Team and co-chairs its Digital Health Work Group.

While the proposed Medicare reimbursement rule was a significant step for CMS, providers should be looking to their policymakers for further remote patient monitoring and connect health support, he added.

“In my opinion, CMS has done everything within its authority to encourage providers to use these new technologies, and the only notable limitations remaining are statutory in nature,” he said. “This means that only Congress has the power to significantly expand Medicare coverage of telehealth services (e.g., eliminating the rural geographic or originating site limitations) and would do so by amending the Social Security Act.”

“Congress did just that earlier this year with regard to stroke and ESRD [end-stage renal disease] services,” he continued. “We may see more from Congress.”

With the backing of new CPT codes from the AMA, healthcare leaders and policymakers are sure to see how providers value connected health services to improve care quality and reduce healthcare costs.

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CHICAGO—The American Medical Association (AMA) today announced the release of the 2019 Current Procedural Terminology (CPT^®) code set. There are 335 code changes in the new CPT edition reflecting the CPT Editorial Panel and the health care community’s combined annual effort to capture and describe the latest scientific and technological advances in medical, surgical and diagnostic services.

“The CPT code set is the foundation upon which every element of the medical community—doctors, hospitals, allied health professionals, laboratories and payers—can efficiently share accurate information about medical services,” said AMA President Barbara L. McAneny, M.D. “The latest annual changes to the CPT code set reflect new technological and scientific advancements available to mainstream clinical practice, and ensure the code set can fulfill its trusted role as the health system’s common language for reporting contemporary medical procedures. That’s why we believe CPT serves both as the language of medicine today and the code to its future.”

Among this year’s important changes to CPT are code additions that reflect the tremendous potential of using connected health tools to better support clinicians in patient population health and care coordination services, and other novel delivery systems that are vital for improving the overall quality of health care.

These include three new remote patient monitoring codes that reflect how health care professionals can more effectively and efficiently use technology to connect with their patients at home and gather data for care management and coordination. Also, two new interprofessional internet consultation codes have been added to reflect the increasing importance of using non-verbal communication technology to coordinate patient care between a consulting physician and a treating physician.

“The AMA has urged the Centers for Medicare and Medicaid Service to adopt the new codes for remote patient monitoring and internet consulting and designate the related services for payment under federal health programs in 2019,” said Dr. McAneny. “Medicare’s acceptance of the new codes would signal a landmark shift to better support physicians participating in patient population health and care coordination services that can be a significant part of a digital solution for improving the overall quality of medical care.”

Additional CPT changes for 2019 include new and revised codes for skin biopsy, fine needle aspiration biopsy, adaptive behavior analysis, and central nervous system assessments including psychological and neuropsychological testing. Broad input from practicing physicians, medical specialty societies and the greater health care community was considered by the CPT Editorial Panel to produce the latest practical enhancements to CPT that reflect the coding demands of the modern health care system.

New CPT category I codes are effective for reporting as of Jan. 1, 2019. To assist the health care system in an orderly annual transition to a new CPT code set, the AMA releases each new edition four months ahead of the Jan. 1 operational date and develops an insider’s view with detailed information on the new code changes.

The AMA invites the health care community to learn more about the significant changes to CPT codes and descriptors by attending the CPT and RBRVS 2019 Annual Symposium in Chicago from Nov. 13-16, 2018. For additional information and registration, please visit the AMA website.

The 2019 CPT codes and descriptors can be imported straight into existing claims and billing software using the downloadable CPT 2019 Data File. The file contains the updated code set’s complete descriptor package, including official descriptors for consumers and physicians, and the complete official CPT coding guidelines.

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[pdf-embedder url=”https://drmiltie.com/wp-content/uploads/2018/07/2019-Medicare-Physician-Fee-Schedule-and-Quality-Payment-Program-CMS-Proposed-Rule-CPT-Codes-990X0-990X1-and-994X9-2018-07-12.pdf” title=”2019 Medicare Physician Fee Schedule and Quality Payment Program – CMS Proposed Rule – CPT Codes 990X0, 990X1, and 994X9 – 2018-07-12″]

CMS’ explanation for its bold, new proposal: “We now recognize that advances in communication technology have changed patients’ and practitioners’ expectations regarding the quantity and quality of information that can be conveyed via communication technology. From the ubiquity of synchronous, audio/video applications to the increased use of patient-facing health portals, a broader range of services can be furnished by health care professionals via communication technology as compared to 20 years ago.”

The biggest takeaways from the proposed 2019 Medicare Physician Fee Schedule and Quality Payment Program with regard to remote patient monitoring (Chronic Care Remote Physiologic Monitoring):

CMS introduced three new RPM codes, retitled “Chronic Care Remote Physiologic Monitoring,” which largely adopt the new codes created by the American Medical Association in 2017.  The codes (CPT 990X0, 990X1, and 994X9) are intended to better reflect how RPM services can be delivered to patients.

Even before these new codes were proposed, separate billing Medicare for RPM has been allowed using CPT 99091, defined as:  “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 (where applicable) requiring a minimum of 30 minutes of time.”

The three biggest takeaways from the new RPM codes that differ from the current CPT 99091 are as follows:

1. Less treatment time required to qualify for reimbursement. CPT 99091 requires at least 30 minutes per 30-day period, whereas CPT 994X9 requires only 20 minutes per calendar month.  The new code is much easier to track on a monthly basis, and requires 33 percent less time.

2. Separate payment for initial set-up and patient education. CPT 99091 does not offer additional reimbursement for the time spent setting up the RPM equipment or educating the patient on its use.  The new codes offer separate reimbursement for the work associated with onboarding a new patient, setting up the RPM equipment and training the patient on same. This is a very helpful move to further incentivize providers to start using these technologies with their patients. In addition, this separate payment is different from how Medicare reimburses Durable Medical Equipment (DME) suppliers (e.g., CPAP, oxygen, etc.). CMS requires the DME supplier to set up the equipment at the patient’s home and educate the patient on how to use the equipment, but does not offer separate payment for that work.
3. Clinical staff allowed. CPT 99091 is limited only to “physicians and qualified health care professionals” and does not expressly allow the RPM service to be delivered by clinical staff (e.g., RNs, medical assistants, etc.). This means the physician or qualified health care professional must perform the full 30 minutes per 30-day period, which is a lot of time for these highly trained professionals. For some providers, this is too resource-intensive to justify the $58.68 per month reimbursement rate.  The new code allows RPM services to be performed by clinical staff.

The only manner in which a Medicare provider could potentially use clinical staff for CPT 99091 is by complying with all the requirements for “incident to” billing, which – among other things – requires that auxiliary personnel be under the direct supervision of the physician. Under Medicare rules, direct supervision means 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.

Most RPM services are best provided via 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 is a huge difference in operations and business models, but in order for CMS to make these new RPM codes work in the real world, it is near-essential that CMS allow RPM to be delivered “incident to” under general supervision.

Healthcare providers should begin launching RPM programs:

Healthcare providers service Medicare patients should consult with companies, such as Dr. Miltie, to deliver RPM services to patients, similar to what we have seen with Chronic Care Management (CCM) companies. This is because the new codes expressly allow the use of “clinical staff” to help fulfill part of the 20 minutes per month. Current CMS guidance on CCM services expressly contemplates and allows third-party companies to contract with Medicare providers to help deliver CCM services. In order to further enable that, CMS created an exception allowing a Medicare provider to bill CCM services as “incident to” under general supervision. Normally, most services billed incident to must be provided under the direct supervision of the provider.  

Healthcare providers should prepare for these new opportunities:

The first thing is to take the time to truly understand, with precision, the billing and supervision rules fundamental to a compliant RPM service model. Providers should not focus too much on the technology and business development until they are confident the model they are “selling” or delivering does, in fact, comply with Medicare billing requirements.

Second, providers should take time to develop a model business-to-business RPM contract with Dr. Miltie, whether this is technology-only, support services-only or a combination of both.

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