Introduction
In July, the Centers for Medicare & Medicaid (CMS) unveiled the CMS 2024 Proposed Medicare Fee Schedule (PFS). Some significant updates, additions, and clarifications could impact your medical practice.
CMS Proposed Several Clarifications Related to Remote Patient Monitoring and Remote Therapeutic Monitoring
Patient Eligibility:
In the 2021 Final Rule, CMS mandated that Remote Services could only be billed for an “established” patient, implying a previous face-to-face visit. Exemptions were granted to this regulation during the Public Health Emergency (PHE). Now that the PHE has expired, CMS will grandfather in any previously enrolled patients as eligible, but going forward, they are reiterating the return to the “established patient” rule.
RPM Requirement of 16 Days of Readings
There has been a strong outcry that many patients and conditions can benefit from less than 16 days of readings. Despite strong evidence that was presented, CMS reiterated the original 16-day requirement and did not recommend new codes for fewer days of monitoring. This 16-day requirement was also clarified as applying to Remote Therapeutic Monitoring (RTM) as well.
Can RPM and RTM be billed concurrently?
CMS clarified that patients may not concurrently enroll in RPM and RTM.
Use of Multiple Medical Devices in RPM
CMS reiterated that even when patients are provided and using multiple medical devices, the services associated with all these medical devices can only be billed once per patient per 30-day period.
CMS reconfirmed that when patients are provided and using more than one medical device, (i.e. blood pressure cuff and pulse oximeter) CPT code 99454 can only be billed once per patient per 30-day period. Please note that this time requirement differs from the other RPM codes, which are time-based and work with a monthly time frame.
Regarding the full range of remote care management services, CMS stated its intentions to “allow maximum flexibility for a given practitioner to select the appropriate mix of care management services,” reinforcing that RPM and RTM (but not both together) could be provided along with Chronic Chronic Care Management (“CCM”), Behavioral Health Integration (“BHI”), Transitional Care Management (“TCM”), Chronic Pain Management (CPM), and Principal Care Management (“PCM”) as long as the time recorded in one program is NOT also applied to another program. In other words, no double-dipping of minutes.
Because of the depth and variety of clinical services we offer at RPM Logix, we frequently can properly bill dual programs like RPM and CCM together in the same month for most patients.
GOOD NEWS FOR FQHCS AND RHCS
Since the introduction of RPM and RTM, Federally Qualified Health Centers (“FQHCs”) and Rural Health Clinics (“RHCs”) have been lobbying unsuccessfully to be eligible to bill RPM and RTM programs. For 2024, CMS has proposed the change to allow FQHCs and RHCs to bill CPT Code G0511 for RPM and RTM services.
New Proposed Programs
CMS took important steps to support value-based care and community-based programs.
Here are 3 new programs:
Community Health Integration (CHI)
This will involve assessment of social determinants of health (SDOH) and encourage proper diagnosis and treatment of community health conditions.
Principal Illness Navigation (PIN)
This program will be for patients with high-risk conditions like cancer, behavioral health, and heart disease. The PIN program will assist patients with community support resources and clinical services.
SDOH Risk Assessment
This would provide new codes and payment for an optional Social Determinants of Health Risk assessment that can be added to the Medicare Annual Wellness Visit (AWV). This code will allow for billing on the same service date as an E&M code.
Summary
RPM Logix is keeping a close eye on the expansion of Remote Therapeutic Monitoring (RTM) and has programs and services ready to roll out once the actual economics are published by CMS.
In anticipation of the new SDOH initiatives, we have expanded our software capabilities to capture these assessments inside our software platform. Stay tuned for updates on how your practice will be able to benefit from the new CHI, PIN, and SDOH programs.