CMS 2021 Rules on Remote Patient Monitoring Fees
CMS has clarified the five primary CPT codes for remote patient monitoring billing and fees
Summary
CMS has provided policies related to remote patient monitoring reimbursement.
Five primary Medicare CPT codes covers initial set-up, supplies & equipment, data analysis, treatment plan development and management.
Billing is limited to one billing, with one practitioner during a 30-day period regardless of number of devices.
Background
Originally limited to patients with chronic disease, however, the new Medicare (CMS) Remote Patient Monitoring (RPM) rules have been updated to include acute conditions as well.
RPM includes the collection and analysis of patient physiologic data used to develop and manage a treatment plan for a patient.
Five primary RPM CPT codes: 99453; 99454; 99457; 99458; 99091.
An established patient relationship must exist to bill CMS under the RPM codes. These rules were waived during the COVID-19 emergency, but will be required once the emergency is over.
Review
RPM services can only be billed by practitioners who are eligible to bill CMS for Evaluation & Management Services (E/M).
o Clinical staff and auxiliary personnel can provide services under the general supervision of the billing provider.
o RPM services cannot be furnished nor billed by an Independent Diagnostic Testing Facility.
The RPM device MUST automatically:
o Upload patient physiologic data (self-recording or self-reporting by patient not allowed)
o Data must be reasonable & necessary for diagnostic or treatment of patient illness or injury in order to improve function.
o Data is to be used to allow understanding of the patient’s health status in order to develop and manage a treatment plan.
Interactive Communication with a Patient Rules:
o Real time synchronous two-way audio interaction capable of being enhanced with video or other data transmission.
o 20 minutes per month of associated with CPT codes 99457 & 99458 is NOT limited to “interactive communication. Rather, it includes time engaged in interactive communication AND non-face to face case care management services. This includes:
i. Review & analysis
ii. Interpretation
iii. Development of treatment plan
iv. Treatment management including patient communication
o The RPM codes for monitoring (99453 & 99454) cannot be reported for a patient more than once during a 30-day period, even if multiple devices are supplied to the patient.
i. Monitoring must occur for at least 16 days of a 30-day month.
ii. Only 1 practitioner can bill during a 30-day period even if multiple providers provide RPM.
Conclusions
These reimbursement rules outline the ability of RPM services to drive patient care.
These rules build upon the telehealth momentum with the COVID-19 emergency.
These should help improve access.
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