A HIMSS article provides a great answer to this question: "RPM can be an especially safe and useful method of care as our healthcare system works to combat COVID-19. This connected care technology is uniquely helpful for treatment and care during a pandemic such as COVID-19 since it allows clinicians to monitor temperature and pulmonary function, blood pressure, and other appropriate physiology for changes in a patient's disease and symptom progression…
"Clinicians and clinical staff can communicate modifications in medication and other self-care to the patient and provide answers to patient questions. If symptoms and the disease progress to the point that hospital services are needed, providers will be able to arrange for care and transport that will ensure safety of the patient and health personnel…
"For patients who test positive for COVID-19, home-based monitoring for symptom escalation can help reduce the risk of transmission and can target the provision of hospital-based care on a timely basis, should the need arise. As we face a growing hospital bed shortage, allowing for this type of remote monitoring can free up valuable and critical hospital resources to treat the most critical cases."
In March 2020, CMS issued specific guidance concerning RPM in its "Medicare and Medicaid Programs; Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency" interim final rule.
As the previously cited HIMSS article notes, CMS made several changes to how it covers RPM. These are changes for the duration of the pandemic and some permanent fixes. They include the following:
Many commercial payers are following the new Medicare guidelines for RPM during the pandemic. Some states have also included RPM into their telehealth parity laws.
Yes. The COVID-19 Telehealth Program was established by the Federal Communications Commission (FCC) in response to the COVID-19 pandemic. Through the program, the FCC is distributing $200 million Congress appropriated under the Coronavirus Aid, Relief, and Economic Security (CARES) Act to help providers deliver telehealth services to patients at their homes or mobile locations. RPM platforms and services are eligible for COVID-19 Telehealth Program funding. Eligible healthcare providers may apply to receive funding support through the COVID-19 Telehealth Program for eligible services and devices purchased on or after March 13, 2020.
The U.S. Food and Drug Administration (FDA) issued guidance to expand the availability and capability of non-invasive RPM devices to facilitate patient monitoring while reducing patient and healthcare provider contact and exposure during the pandemic. Several devices are included in the guidance, such as FDA-cleared non-invasive blood pressure devices, pulse oximeters, cardiac monitors, and electrocardiograph (ECG) devices.
The FDA's policy, which is limited to the duration of the public health emergency, details how the FDA does not intend to object to companies making modifications in product indications, claims, functionality, or limited modifications to hardware and software.
Five things you should know during the crisis about providing telehealth services and chronic care management like remote patient monitoring to patients.
RPM is the use of digital technologies to monitor and capture medical and other health data from patients and electronically transmit this information to healthcare providers for assessment and, when necessary, recommendations and instructions. RPM allows providers to continue tracking healthcare data for patients once they are discharged. It also encourages patients to take more control of their health.
Providers can use RPM to collect a range of patient health data, including blood pressure, vital signs, weight, heart rate, blood sugar levels, and physical activity.
RPM can employ wired or wireless measurement devices. The most common RPM devices are blood pressure monitors, weight scales, cardiac implants, and blood glucose meters. Pulse oximeters have also become more common due to the COVID-19 pandemic.
Physicians and other qualified healthcare professionals (QHCPs) can provide and bill for RPM. Clinical staff can furnish and manage RPM under the general supervision of the billing provider.
Any patient. With that said, a provider should only order/prescribe RPM if captured data is directly relevant to managing a patient's condition(s) (i.e., medical necessity), with such justification documented in the medical record.
RPM provides a wide range of benefits, including the following:
Since each RPM program is different, the steps to set up programs will vary. The amount of work that providers must complete will differ by RPM program, but these are the general steps for providers who choose to deliver RPM services with minimal external support:
While this may seem like a lengthy list, a good RPM program vendor will perform many of these steps, thereby reducing the effort and management required from the provider and staff.
This will largely depend upon the RPM device and how data is transmitted from patient to provider. Some devices require patients to access one or more of the following: Wi-Fi; smartphone (in some instances, newer models); and personal computer. Other devices may only require the device itself. Such devices use cellular data to transmit information.
Depending upon the design and/or complexity of the device, patients may need in-person or virtual assistance to set up and use the technology.
Where RPM data is stored will depend upon the device. Typically, data is captured and transmitted via a Wi-Fi or cellular network to a central data repository. Types of repositories include an electronic health record (EHR) system or personal health record.
Older devices often stored the information on the device itself, which then required patients to convey the information to their providers. This type of workflow is no longer considered RPM by Medicare and the vast majority of other payers.
RPM is considered a specific subset of telehealth. One can use the phrase ‘telehealth’ to refer to RPM, but telehealth can also refer to many other types of remote healthcare services.
RPM is the use of a device for interaction between providers and patients outside of the provider’s organization. Telehealth is the use of electronic information and telecommunications technologies to support long-distance clinical care, patient and professional health-related education, public health, and health administration.
Yes, and providers must obtain and document consents in patients' medical records. Medicare allows for informed verbal consent, but other payers may require written.
Due to COVID-19, CMS temporarily modified the requirement that consent must be obtained prior to providing an initial RPM service. Practitioners can now obtain consent at the time services are provided and by individuals providing RPM services under contract to the ordering physician or qualified healthcare professional.
Like any healthcare program, providers should follow HIPAA security and privacy regulations. Providers should ensure that their RPM devices and technology are compliant with FDA standards. Technology that meets FDA standards can help ensure quality control and assurance, data accuracy, and compliance. Finally, providers will want to ensure that their RPM programs follows the most current coding and billing rules.
This essentially boils down to carefully vetting RPM vendors and their devices. Vendors should build their devices so that patient data is encrypted when it is in transit — from patient to provider and vice versa — and when the device that stores the data is not in use.
There are a variety of programs and vendors providers can choose from. Generally speaking, they can be broken down into two types: full-service programs and those requiring a self-managed approach. The following summarizes the essential differences between these programs:
Our billing guide offers vital information on new CPT codes, billing flow, service requirements and reimbursement.
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RPM is payable by Medicare, 21 state Medicaid programs (as of January 2021), and an increasing number of private payers. Some states, such as Louisiana, have mandated that all private insurers operating in the state must cover some form of RPM. In 2020, the CPT codes for RPM were overhauled, making it one of the most lucrative Medicare care management programs.
There is a small payment for initial patient enrollment, and a monthly base payment for management of the device and patient readings. There is an optional service for each 20 minutes of care management — which can be provided by clinical staff — up to 60 minutes total.
Yes, via CPT code 99453. See the FAQ "What CPT codes cover RPM and how much are they reimbursed by Medicare?" below for more details.
Essentially, no. As long as patients are not in a shared space with the provider delivering the RPM services, they can receive these services. This means patients can be in their homes, on vacation, in a skilled nursing facility, at work, or any other location where the service can be provided.
See if remote patient monitoring is the right answer for your practice. Learn the advantages and limitations of the different technologies used.
As of April 2020, they are as follows:
* Amounts identified are approximate. Reimbursement varies among Medicare administrative contractors (MACs).
Note: CPT code 99091 was the original way to bill for remote patient monitoring. Over the past several years, its limitations and requirements had made it rarely reported due to the availability of the newer codes listed above. However, the 2021 Medicare physician fee schedule final rule might change the frequency that CPT 99091 is reported as CMS now permits billing the code with newer codes. In other words, providers can bill for "complex" RPM management when the provider must spend significant time managing the patient and their RPM care plan. CMS also stated that 99091 can be billed each 30 days whenever such complex provider management occurs without affecting the practice's ability to bill clinical staff time via CPT 99457 each calendar month.
99457 reimburses for time spent by the billing physician, QHCP, or clinical staff, in accordance with laws.
No. Providers may recommend RPM services for any patient who may benefit from the service.
99454 can only be billed once per patient every 30 days. This is regardless of whether the patient is using a single device or multiple devices.
Yes, a provider can bill both the RPM CPT code 99457 and CCM CPT code 99490. CMS recognizes the analysis involved in furnishing RPM services is complementary to CCM and other care management services. With that said, the time spent by providers in furnishing these services cannot be counted towards the required time for RPM and CCM codes for a single month. In other words, no “double counting.” Billing 99457 and 99490 together requires a provider to deliver at least 40 minutes of services: 20 minutes of RPM, 20 minutes of CCM.
For Medicare beneficiaries: Yes. RPM services, like other Medicare Part B services, are subject to a 20% beneficiary copay. This copay is generally not waivable, but it may be covered if a patient has supplemental coverage or Medicaid.
Private payers establish their own copay policies and may choose not to require a copay.
Providers should initially obtain informed beneficiary consent to receive RPM services.
To document CPT 99453, include the following:
For time-based codes (CPT 99457 and 99458), document the time spent on each.
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