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Tuesday, September 26, 2023

Distant Affected person Monitoring (RPM) and Distant Therapeutic Monitoring (RTM): A Deep Dive into Proposed Medicare Adjustments

On July 13, the Facilities for Medicare & Medicaid Providers (CMS) launched its annual Proposed Rule updating the Medicare Doctor Payment Schedule (PFS) for calendar 12 months (CY) 2024, which incorporates varied proposed adjustments associated to the supply of distant physiologic monitoring (RPM) and distant therapeutic monitoring (RTM) providers.

The Proposed Rule, if enacted as proposed, will:

  1. Make clear conditions for billing sure RPM and RTM codes;
  2. Make clear that Medicare can pay individually for RPM and RTM throughout world surgical procedure intervals;
  3. Enable separate fee of RPM and RTM for federally certified well being facilities (FQHCs) and rural well being clinics (RHCs);
  4. Enable bodily remedy assistants (PTAs) and occupational remedy assistants (OTAs) to supply RTM underneath the overall supervision of bodily therapists (PTs) and occupational therapists (OTs); and
  5. Add RPM to the definition of major care providers used for functions of Medicare Shared Financial savings Program (MSSP) beneficiary task.  

Additionally of explicit observe, via the 2024 Proposed Rule, CMS is requesting data from stakeholders on varied RPM/RTM subjects in addition to associated digital therapies, together with digital cognitive behavioral remedy (CBT). 

RPM and RTM Clarifications

RPM Can Solely be Furnished to an “Established Affected person”

Within the 2021 Ultimate Rule, CMS said that RPM providers are restricted to “established sufferers.” In assist of this place, CMS asserted {that a} doctor who has a longtime relationship with a affected person would doubtless have had a possibility to supply a brand new affected person Analysis and Administration (E/M) service. Throughout that new affected person E/M service, the doctor would have collected related affected person historical past and carried out a bodily examination, as acceptable. In consequence, the doctor would possess data wanted to know the present medical standing and desires of the affected person previous to ordering RPM providers to gather and analyze the affected person’s physiologic knowledge and to develop a remedy plan. CMS waived the “established affected person” restriction in the course of the Public Well being Emergency (PHE) however within the 2021 Ultimate Rule, CMS declined to increase such waiver past the PHE. Sometimes, this can require the practitioner to conduct a brand new affected person E/M service prematurely of initiating RPM providers.

Within the 2024 Proposed Rule, CMS supplies clarification that sufferers who acquired preliminary distant monitoring providers in the course of the PHE are thought of established sufferers.

It’s notable that CMS expressly references solely RPM (and never RTM) when clarifying the requirement that providers might solely be furnished to an “established affected person.” Thus, stakeholders ought to request that CMS make clear whether or not the “established affected person” requirement applies to each RPM and RTM providers.

Requirement to Accumulate 16 Days of Information Stays

Within the Proposed Rule, CMS supplies clarification that despite the fact that CMS has acquired varied feedback and inquiries about modifying its minimal knowledge assortment necessities for distant monitoring, as of the tip of the PHE, the 16-day monitoring requirement was reinstated, which means monitoring should happen over not less than 16 days of a 30-day interval.

Moreover, it’s notable that CMS expressly lists RTM CPT (Present Procedural Terminology) codes (98976, 98977, 98978, 98980, and 98981) as those who rely on assortment of no fewer than 16 days of information in a 30-day interval. Final 12 months, in its proposed 2023 Medicare Doctor Payment Schedule, CMS proposed a requirement that not less than 16 days of information should be reported throughout a 30-day interval to invoice the RTM skilled codes (CPT codes 98980 and 98981). Nonetheless, CMS in the end didn’t finalize this proposal within the 2023 last rule. It seems CMS is as soon as once more re-instating this proposal. If this proposed clarification is finalized, the RTM skilled codes couldn’t be used to handle the remedy of a situation if the monitoring providers didn’t embody not less than 16 days of information. Moreover, by particularly referencing solely the RTM codes, CMS doubtlessly introduces uncertainty with respect whether or not it additionally intends these limitations to use to the RPM skilled codes (CPT codes 99457 and 99458).

Since separate funds for RPM and RTM providers have been established, trade stakeholders have advocated towards this 16-day requirement arguing that it’s clinically arbitrary and ignores circumstances the place a diminished variety of days can be extra clinically acceptable.

stakeholders ought to think about submitting feedback advocating for larger flexibility on the 16-days requirement and what nuances apply solely to RTM, solely to RPM, to each units of codes, or solely to a few of the RPM or RTM codes, however not others.

Solely One Practitioner Can Invoice RPM/RTM

Within the 2024 Proposed Rule, CMS reiterates that for both RPM or RTM, just one practitioner can invoice CPT codes 99453 and 99454, or CPT codes 98976, 98977, 98980, and 98981, throughout a 30-day interval and solely when not less than 16 days of information have been collected on not less than one medical gadget. “Even when a number of medical units are offered to a affected person,” CMS defined, “the providers related to all of the medical units will be billed by just one practitioner, solely as soon as per affected person, per 30-day interval, and solely when not less than 16 days of information have been collected.” CMS additionally reemphasizes that remotely monitored month-to-month providers ought to be reported solely when fairly needed. These ideas are per earlier CMS steering.

It’s notable that CMS doesn’t expressly checklist the CPT codes for RPM remedy administration providers (CPT codes 99457, 99458) when reiterating that just one practitioner can invoice these codes. stakeholders ought to think about requesting CMS make clear whether or not multiple practitioner can invoice CPT codes 99457 and 99458 for a similar affected person in the identical month.

Use of RPM / RTM with Different Providers

CMS reiterates practitioners might invoice RPM or RTM (however not each RPM and RTM) concurrently with the next care administration providers for a similar affected person so long as time or effort usually are not counted twice: Persistent Care Administration (CCM), Transitional Care Administration (TCM), Behavioral Well being Integration (BHI), Principal Care Administration (PCM), or Persistent Ache Administration (CPM) codes.

CMS additionally references the 2023 CPT Codebook Steering that “RPM and RTM is probably not billed collectively” to make sure that no time is counted twice by billing for concurrent RPM and RTM providers and to clarify that the identical affected person can’t obtain RPM and RTM providers in the identical month. CMS particularly equates a affected person receiving RPM and RTM in the identical month to a supplier billing RPM a number of instances in a single month the place there may be greater than as soon as gadget, which on this steering and previous steering, Medicare has made clear is just not permissible.

Stakeholders who disagree with this place and interpretation ought to search readability from CMS concerning why RPM and RTM being billed concurrently so long as time is just not counted twice is handled any in another way than billing RPM or RTM with different care administration providers, which is permitted so long as time is just not counted twice. 

Separate Cost of RPM or RTM Throughout World Surgical procedure Intervals

CMS clarifies that the place a affected person receives a process or surgical procedure, and associated providers, that are lined underneath a fee for a world interval, RPM or RTM (however not each) could also be furnished individually to the affected person and Medicare would pay for the RPM or RTM providers, separate from the worldwide service fee, as long as different necessities for the worldwide service and every other service in the course of the world interval are met. Equally, for a affected person who already is receiving RPM or RTM providers throughout a world interval, a practitioner might furnish RPM or RTM providers (however not each) to the affected person, and Medicare can pay the practitioner individually for the RPM or RTM, as long as the distant monitoring providers are unrelated to the analysis for which the worldwide process is carried out, and so long as the aim of the distant monitoring addresses an episode of care that’s separate and distinct from the episode of take care of the worldwide process – which means that the distant monitoring providers deal with an underlying situation that isn’t linked to the worldwide process or service.

Permitting Separate Reimbursement for RHCs and FQHCs

For a number of years, RPM and RTM codes have been billable by physicians and doctor teams, however FQHCs and RHCs haven’t been approved to invoice individually for these providers. Usually, when these providers are furnished incident to a doctor or different skilled’s service throughout an FQHC or RHC go to, fee is made via the all-inclusive fee.

CMS is proposing allowing FQHCs and RHCs billing RPM/RTM utilizing the overall care administration code, Healthcare Frequent Process Coding System (HCPCS) code G0511 on an FQHC or RHC declare kind; offered that RPM/RTM providers are medically cheap and needed, meet all the necessities, and usually are not duplicative of providers paid to RHCs and FQHCs underneath the overall care administration code for an episode of care in a given calendar month.

CMS additional proposes to revise the way it calculates the fee quantity for G0511. Presently, CMS makes use of an unweighted common of the assorted codes included inside HCPCS Code G0511. CMS states that because of the decrease medical depth of RPM and RTM, including the RPM and RTM codes would consequence within the discount of the G0511 fee quantity from a month-to-month fee of $77.94 to a fee of $64.13. CMS proposes as an alternative to make use of a weighted common, which might end in a fee of $72.98 for the mixed code. CMS is particularly looking for touch upon its proposal to revise the fee fee methodology for G0511.

Stakeholders ought to think about submitting enter referring to how HCPCS Code G0511 will probably be valued going ahead and requesting clarification on how practitioners ought to deal with medical situations the place each RPM/RTM could also be used concurrently with different care administration codes (e.g., CCM).

PTs and OTs Can invoice RTM for PTAs and OTAs underneath Basic Supervision

In prior rulemaking, CMS clarified that PTs and OTs can present and invoice for RTM providers. Nonetheless, present Medicare rules require all bodily and occupational remedy providers be carried out by, or underneath the direct supervision of, the PT or OT. Within the Proposed Rule, CMS acknowledges requiring direct supervision makes it tough for PTs and OTs to invoice for the RTM providers carried out by the PTAs and OTAs they’re supervising. In consequence, CMS is proposing to determine an RTM-specific basic supervision coverage that will permit RTM to be offered by an PTA or OTA underneath basic supervision of the PT or OT, respectively.

RPM Included in Definition of Major Care Providers for MSSP

CMS proposes so as to add RPM CPT codes 99457 and 99458 to the definition of major care providers used for functions of beneficiary alignment within the MSSP. This may occasionally serve to develop the scope of beneficiaries who obtain RPM and extra precisely assign beneficiaries to Accountable Care Organizations primarily based on who the affected person acquired RPM providers from.

Request for Data on RPM, RTM and Digital Therapies

CMS is looking for data on how distant monitoring providers, similar to RPM and RTM, are utilized in medical observe with a concentrate on digital CBT. Particularly, CMS asks a number of pages of questions associated to the next subjects:

  • How practitioners would determine which sufferers would profit from digital therapeutics and the way practitioners would monitor their effectiveness.
  • Requirements which were developed to make sure the privateness and safety of digital therapeutics for behavioral well being.
  • Efficient fashions for the distribution or supply of digital therapies and finest practices to assist and practice sufferers.
  • Which practitioners and auxiliary workers are concerned in furnishing RPM and RTM.
  • How knowledge are collected and maintained for recordkeeping and care coordination.
  • How an episode of care ought to be outlined, significantly when one affected person could also be receiving concurrent RTM or digital CBT providers from two distinction clinicians engaged in separate episodes of care.
  • How permitting a number of, concurrent RTM providers for a person may have an effect on entry to care, affected person prices, high quality, well being fairness, and program integrity.
  • The professionals and cons of generic versus particular RTM gadget codes.
  • What proof CMS ought to think about when figuring out whether or not digital therapeutics are cheap and needed.
  • What features of digital therapeutics for behavioral well being ought to be thought of when figuring out whether or not they match right into a Medicare profit class, and which class ought to be used.
  • If CMS determines that providers match inside an present Medicare profit class, what features of digital CBT providers ought to be thought of when figuring out potential fee (together with whether or not these providers are furnished incident to or impartial of a go to).
  • Boundaries to accessing digital CBT for underserved populations and techniques to handle these entry limitations.

Stakeholders with an curiosity in increasing availability and protection for digital therapies, together with software program as a medical gadget and prescription digital therapeutics ought to think about commenting on the rule in hopes of increasing future protection for all these providers. 

Make Your Voice Heard

Suppliers, know-how firms, and digital care entrepreneurs considering distant monitoring ought to think about offering feedback to the Proposed Rule. CMS is soliciting feedback on the Proposed Rule till 5:00 p.m. on September 11, 2023. Anybody might submit feedback – anonymously or in any other case – through digital submission at https://www.rules.gov/. Alternatively, commenters might submit feedback by mail to:

  • Common Mail: Facilities for Medicare & Medicaid Providers, Division of Well being and Human Providers, Consideration: CMS-1784-P, P.O. Field 8016, Baltimore, MD 21244-8016.
  • Categorical In a single day Mail: Facilities for Medicare & Medicaid Providers, Division of Well being and Human Providers, Consideration: CMS-1784-P, Mail Cease C4-26-05, 7500 Safety Boulevard, Baltimore, MD 21244-1850.

If submitting through mail, please make sure to permit time for feedback to be acquired earlier than the deadline.


The CMS Proposed Rule advances the power of RPM and RTM providers to drive income and enhance the affected person care expertise. We’ll proceed to watch CMS for any rule adjustments or steering that have an effect on or enhance RPM and RTM alternatives.

For extra data on telemedicine, telehealth, digital care, distant affected person monitoring, digital well being, and different well being improvements, together with the workforce, publications, and consultant expertise, go to Foley’s Telemedicine & Digital Well being Business Staff.

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