CMS updates Medicare remote patient monitoring standards

November 22, 2023

Blog Post

The Centers for Medicare & Medicaid Services (CMS) updated Medicare billing standards for remote physiologic monitoring (RPM) and remote therapeutic monitoring (RTM) and provided related guidance in the Medicare Physician Fee Schedule (MPFS) 2024 Final Rule.

Medicare pays physicians and other healthcare providers under RPM CPT codes to monitor patient physiologic parameters and RTM CPT codes to monitor respiratory systems, musculoskeletal systems and cognitive behavioral therapy. RPM and RTM codes cover initial set-up of a medical device and patient education on use of the device, monthly supply of the medical device and transmission of recordings or alerts, and monthly RPM or RTM treatment management services.

Minimum 16 days of data collection

CMS clarified that data is required to be collected for at least 16 days in a 30 day billing period to bill under the RPM and RTM supply and transmission codes, but noted the 16-day requirement does not apply to the RPM and RTM treatment management codes 98980 and 98981 for RTM and 99457 and 99458 for RPM. The MPFS 2024 proposed rule included RTM treatment management codes in the list of remote patient monitoring codes, requiring collection of at least 16 days, and it indicated that all RPM and RTM codes required at least 16 days of data collection.

Established patient requirement

CMS allowed RPM and RTM services to be furnished to either established or new patients during the PHE, but since the end of the COVID-19 Public Health Emergency (PHE), it has required an established patient relationship for RPM. An established patient is generally a patient who within the last 3 years has received professional services from the physician or another healthcare professional, with the same specialty, who belongs to the same group practice. CMS also recognizes that patients who received initial remote monitoring services during the PHE are considered established patients.

CMS clarified in the Final Rule that RPM, but not RTM, services require an established patient relationship. CMS, however, expressed the expectation that RTM services would be furnished to a patient after a treatment plan has been established and that, presumably, the treatment plan would be established after initial interaction with the patient. CMS said it will work to clarify this policy and hopes to continue dialogue with interested parties. This commentary suggests that while an established patient relationship isn’t necessarily required for RTM services, failure to establish a treatment plan before commencing RTM could raise concerns in a billing audit, particularly for new patients.

RPM and RTM services during global surgery periods

CMS clarified that a practitioner can furnish and receive payment for RTM or RPM services during a global surgery period if the remote monitoring addresses an underlying condition that is not linked to the global procedure or service. CMS also stated that RTM and RPM services are permitted during a global surgery period if the practitioner, such as a physical or occupational therapist, furnishing the RTM or RPM does not furnish the global procedure or receive global service payment.

Expansion of RPM and RTM billing to FQHCs and RHCs

Federally qualified health centers, or FQHCs, and rural health clinics, RHCs, which are currently not allowed to bill for RPM and RTM services, will be allowed to bill for RPM and RTM under HCPCS general management code G0511 starting in January 2024.

Other clarifications and restatements

In addition, CMS reiterated earlier guidance on various RPM and RTM principles, including:

Only one practitioner is allowed to bill RPM or RTM codes during a 30 day period
Even if multiple medical devices are provided to a patient RPM or RTM services can be billed only once per patient during a 30 day period
RPM or RTM services can be billed concurrently with chronic care management, transitional care management, principal care management, chronic pain management or behavioral health integration for the same patient absent double counting, provided that RPM and RTM can not be billed together.

For more information on RPM, RTM or the Medicare Physician Fee Schedule 2024 Final Rule, please contact a member of McDonald Hopkins' national Healthcare Practice Group.

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