Remote Patient Monitoring: Contract Structures, Medicare Coverage, and Regulatory Compliance

Wednesday, February 15, 2023 | 1:00 PM - 2:30 PM ET

Speaking Engagement

McDonald Hopkins' Rick Hindmand will be speaking as part of a panel in this virtual webinar presented by Strafford.

Since Medicare began paying for RPM services in 2018 the Centers for Medicare & Medicaid Services (CMS) has expanded RPM coverage with additional codes and guidance, and in 2022 began covering RTM. On Nov. 1, 2022, CMS released the CY2023 final rule for services reimbursed under the Medicare Physician Fee Schedule (MPFS). The final rule changes to Medicare Part B professional payment policies and rates for 2023. The final rule allows payment under new RTM device codes for cognitive behavioral therapy and loosens supervision standards for RTM. CMS did not finalize its proposal to replace RTM codes with new G codes, which CMS recognized was creating confusion.

CMS has revised Medicare payment policies for remote patient monitoring so that RPM and RTM can be provided "incident to" under general supervision, thereby making it less burdensome for providers to furnish remote patient monitoring services.

Those utilizing RPM or RTM must ensure they comply with licensure, scope of practice, coding and related requirements to be eligible for reimbursement.

Further, patient monitoring has historically been set up in healthcare facilities, while RPM and the associated monitoring equipment are deployed in the patient's home. This difference presents risks, including to data privacy and security. Among other issues, wireless networks, platforms, and devices are susceptible to being hacked, allowing access to sensitive health information, and many questions have arisen about considerations for patients' privacy and the security of their information.

As healthcare provider organizations seek to invest in and utilize RPM or RTM solutions, particularly as patients have become accustomed to remote care during the pandemic, they should consider the risks and compliance challenges to RPM and understand the reimbursement landscape.

Listen as our authoritative panel of healthcare attorneys examines reimbursement and how recent changes impact the landscape for remote patient monitoring. The panel will also address the challenges of remote patient monitoring, such as privacy and security, as well as related compliance considerations.

Over the past 24 months, the U.S. Department of Health and Human Services Office for Civil Rights has brought notable enforcement efforts against several non-profit covered entities and business associates, resulting in instances of six and seven-figure penalties against providers across the county for incidents involving breaches of protected health information.

A new amendment to New York state law, which would have required all healthcare providers to obtain separate consents from patients for treatment and payment is on hold until further guidance is released, according to the New York Department of Health.

On November 1, 2024, the Centers for Medicare & Medicaid Services issued the Medicare Physician Fee Schedule 2025 final rule, which establishes new advanced primary care management billing codes that will expand opportunities for physician practices, federally qualified health centers, rural health clinics and other health care providers to get paid for services provided by clinical staff under the direction of a physician, nurse practitioner or physician assistant beginning January 1, 2025.

Remote Patient Monitoring: Contract Structures, Medicare Coverage, and Regulatory Compliance

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