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.
Prior to COVID-19, the answer to this measurement days question was fairly straightforward: 16. However, a federal waiver issued early in the pandemic permitted providers to deliver and bill for RPM services to those patients with suspected or confirmed cases of COVID-19. The waiver stated that CMS would permit the reporting of RPM services to Medicare for periods of time of fewer than 16 days but no less than two days during the public health emergency (PHE). This became known as Medicare's "2-day RPM requirement." However, what's important to understand is that billing for CPT code 99453 and CPT code 99454 requires usage of a medical device that digitally collects and transmits 16 or more days of data every 30 days for the billing of these codes. Th is referred to as the "16-day RPM requirement."
Some providers and RPM vendors have applied the 2-day RPM requirement to all patients during the PHE. This interpretation is incorrect. In early 2021, CMS stated that the 2-day RPM requirement should only be applied to patients with a suspected or confirmed diagnosis of COVID-19.
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.
Specialties frequently embracing RPM include cardiology, pulmonology, endocrinology, gastroenterology, and bariatrics.
Common disease states managed by RPM include hypertension, obesity, congestive heart failure (CHF), chronic lower respiratory disease (COPD), and diabetes.
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:
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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.
As of spring 2021, the Center for Connected Health Policy (CCHP) reports that 26 states have some form of reimbursement for remote patient monitoring in their Medicaid programs. This is up from 22 states from fall 2020 as four states — North Carolina, North Dakota, Oklahoma, and Ohio — have since added reimbursement for RPM.
However, there are some caveats to some states' RPM coverage. Ohio added reimbursement but only for specific remote physiologic monitoring codes. Many of the states with Medicaid programs that reimburse for RPM have restrictions associated with RPM use. CCHP states the most common of these restrictions include only offering RPM reimbursement to home health agencies, restricting the clinical conditions for which symptoms can be monitored, and limiting the type of monitoring device and information that can be collected. Two states — Hawaii and New Jersey — have laws requiring that Medicaid reimburse for RPM. However, as of spring 2021, these states lacked any official Medicaid policy concerning RPM reimbursement.
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.
In January 2021, remote patient monitoring was included in an announcement by the Office of Inspector General that CMS would be conducting a series of audits of Medicare Part B telehealth services. These Recovery Audit Contractor (RAC) and Medicare Administrative Contractor (MAC) audits are to occur in two phases. RPM was identified as part of the second phase. To learn four of the RPM areas auditors are likely to focus on during audits, click here.
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.
No. CMS has defined interactive communication, as referred to in CPT code 99457 and CPT code 99458, as a conversation occurring in real time that includes synchronous, two-way interactions which can be enhanced with video or other kinds of data. This had been interpreted by some RPM providers and vendors to include texting as an acceptable method for delivering billable interactive communication time. But as of the 2021 Medicare physician fee schedule final rule, this is no longer the case. Time spent texting with patients can be counted towards RPM management time. However, it does not satisfy the requirement for interactive communication. Some billable time for each RPM code must be achieved via audio communication with the patient/caregiver.
No. The confusion around this question concerns the 2020 Medicare physician fee schedule final rule, which seemed to suggest that separate providers could bill RPM services for the same patient as long as the patient used different RPM devices. In 2021, CMS sought to clarify that only one provider could bill CPT code 99453 and CPT code 99454 during a 30-day period. If one or more providers attempt to bill for remote patient monitoring services for a patient already receiving RPM services from another provider, associated claims are likely to be denied. Repeated attempts to bill for RPM in this fashion could lead to compliance challenges.
Not for remote patient monitoring. While self-reporting measurements into a patient portal or app or otherwise manually conveying measurements to providers may qualify for other Medicare covered services, data captured in such a fashion cannot be counted towards Medicare RPM. RPM device measurements must automatically sync with a provider's remote patient monitoring platform without any patient transcription.
In early 2021, CMS made the surprising announcement that it was issuing a correction to its 2021 Medicare physician fee schedule final rule. The correction was welcomed news as it clarified several areas of confusion concerning remote patient monitoring billing requirements while also expanding coverage. To learn about the correction document and key takeaways, click here.
Prevounce's Remote Patient Monitoring platform allows practices to expand patient care outside of their clinic. Learn more about our no-risk RPM trial.
Generally speaking, remote therapeutic monitoring (RTM) is designed to help manage patients using medical devices that collect "non-physiological data." The concept of RTM was introduced by the American Medical Association in 2020.
We don't yet have a clear definition of non-physiological data from CMS. However, the 2022 Medicare Physician Fee Schedule proposed rule indicates that remote therapeutic monitoring is intended to monitor a range of health conditions and patients who would benefit from remote monitoring that falls outside of traditional confines of tracking vitals data via remote patient monitoring (RPM).
In the proposed rule, CMS indicated that potential non-physiologic data includes musculoskeletal system status, therapy/medication response, therapy/medication adherence, and respiratory system status.
Yes. We learned from the proposed rule how CMS expects these two concepts to differ. In short, provider types that cannot bill for RPM may now be able to bill for RTM; RTM data can be collected from medical devices that measure non-physiological data; and RTM, as presently defined, would cover data self-reported by patients, assuming code requirements are met.
As of July 2020, the five remote therapeutic monitoring codes — each with a placeholder at the moment — have the following proposed descriptions:
The proposed rule, for which comments are due to CMS on or before Sept. 13., suggests that coverage for remote therapeutic monitoring could begin as soon as Jan. 1, 2022. This would be unusually fast as CMS typically does not adopt coverage for new CPT services quickly. We'll know more when the 2022 Medicare Physician Fee Schedule final rule is published, if not sooner.
Yes and yes. Remote therapeutic monitoring would also be good for payers. As we understand the proposed codes and coverage, providers would be in a position to address some significant gaps in the current coverage and delivery of remote patient monitoring. RTM services would help patients experience more consistency and quality along the care continuum, especially for chronic disease monitoring.
A lot. Among the matters and issues still requiring clarification: final CPT codes, descriptions, and reimbursement; definition of non-physiologic data; who will be permitted to bill RTM services; what clinical use cases will be eligible for RTM reimbursement; approved devices to collect RTM data; whether self-reported data is acceptable; and if RTM will be considered an "incident to" service, meaning that non-provider clinical staff can furnish a significant amount of the service instead.
The Centers for Medicare & Medicaid Services (CMS) has issued its 2022 Medicare Physician Fee Schedule proposed rule.
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