CMS clarifies Medicare remote patient monitoring standards

In the January 19 Federal Register, the Centers for Medicare & Medicaid Services (CMS) clarified the scope of services that are counted in determining whether minimum time requirements are satisfied under remote patient monitoring (RPM) treatment management billing codes.  

CMS previously stated in the Medicare Physician Fee Schedule (PFS) 2021 proposed rule that only the practitioner’s interactive communication time with the patient would be included for purposes of meeting the monthly 20-minute minimums under codes 99457 (which pays for the first 20 minutes of RPM treatment management time in a calendar month) and 99458 (which pays for additional 20 minutes). Commenters expressed concern that the CMS “interactive communication” standards could be read to suggest that only synchronous, real-time interactive communication time between a practitioner and a patient would be included under codes 99457 and 99458. By excluding review and analysis time from the 20-minute element that interpretation would have severely restricted the financial viability of RPM.

Through this correction, CMS has now revised the preamble to the PFS 2021 final rule to clarify that codes 99457 and 99458 include not only interactive communication time, but also other time furnishing related care management services during the calendar month. CMS indicated in its Fact Sheet for the PFS 2021 final rule that CPT codes 99457 and 99458 can include time furnishing care management services as well as the required interactive communication, although this guidance was not previously reflected in the text of the PFS 2021 final rule. 

CMS also clarified that CPT codes 99453 (for initial set-up and patient education) and 99454 (for monthly supply and transmission) can be billed by only one practitioner and only once per patient per 30-day period. This restriction applies even when multiple medical devices are provided to the patient. CMS noted that when a more specific code is available for billing RPM, the more specific code should be billed. CMS cited CPT codes 95250 (continuous glucose monitoring and codes 99473 and 99474 (self-measured blood pressure monitoring) as examples.

See CMS finalizes Medicare remote patient monitoring policy changes and guidance for a summary of RPM provisions of the PFS 2021 final rule.

For more information on these RPM changes for CY 2021, please contact the attorney below.