Key remote patient monitoring takeaways from the 2024 PFS proposed rule

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The Centers for Medicare & Medicaid Service (CMS) recently published its 2024 physician fee schedule (PFS) proposed rule. One subject receiving a fair amount of attention in the rule is remote physiologic monitoring — i.e., remote patient monitoring or RPM. The agency has included a few proposed changes to RPM, which is typical for a proposed rule. But CMS also chose to call out RPM in another — and unusual — way.

To help get you up to speed on what CMS said about RPM in the proposed rule, here's a summary of key takeaways.

Concurrent RPM and RTM billing

In the proposed role, CMS proposed to clarify that it is permissible to bill for RPM or remote therapeutic monitoring (RTM) services, but not both at the same time. CMS reiterated that RTM or RPM services can be billed concurrently with care management services, such as chronic care management (CCM), transitional care management (TCM), principal care management (PCM), chronic pain management (CPM), and behavioral health integration (BHI), for the same patient if time or effort are not counted and billed for twice. The ability to provide and bill for RPM and CCM concurrently is a big win for patients because of the increase in RPM effectiveness when paired with well-implemented CCM and a big win for providers because of the ability to deliver improved care and be paid for it.

CMS made it clear that its payment policies for the interplay between care management and remote monitoring services are not set in stone. CMS requested comments concerning practitioner experience with different code sets and services that the agency said it will use to develop and further clarify such policies.

In instances when a patient receives both RPM and RTM services and there may be multiple devices used for monitoring, CMS notes that its existing rules would apply in this situation. These rules state that services associated with all medical devices can only be billed:

• by one practitioner;
• only once per patient, per 30-day period; and
• only when at least 16 days of data have been collected.

RPM during global periods for surgery

CMS proposed to clarify its rules concerning the use of remote monitoring during global periods for surgery. The agency stated that for those beneficiaries receiving services during a global period, a provider may furnish RPM or RTM services — but, again, not both — to the individual beneficiary and the practitioner would receive separate payment. An important requirement to note: The remote monitoring services provided must be intended to address an underlying condition not linked to the global procedure or service.

RPM coverage for FQHCs and RHCs

Currently, RPM and RTM codes are not billable by federally qualified health centers (FQHCs) and rural health clinics (RHCs). RPM and RTM are considered "included" within these facilities' all-inclusive rate.

In 2019, CMS split chronic care management out from this "all-inclusive" bundle, thereby allowing CCM to be billed by FQHCs separately under the general care management HCPCS code G0511. This was good news, and many pundits expected RPM to be split out in a separate code soon after.

"Soon after" took longer than expected, but better late than never! For 2024, CMS is proposing to include RPM and RTM in G0511. This has been long advocated for, and it is great to see it finally happen. For 2024, if this proposed change is finalized, G0511 will include:

• Chronic care management
• Principal care management
• Behavioral health integration
• Chronic pain management
• Remote therapeutic monitoring
• Remote physiological monitoring

But there is some uncertainty and strangeness around what this proposed rule change means. Currently, an FQHC can only bill a single G0511 per month regardless of how many care management services it provides. Under this proposal, it seems that both calendar month (e.g., CCM) and rolling 30-day (e.g., RPM device) codes would funnel into the one-unit-per-month G0511 code.

If you can only bill for the device readings or the care management time each month, do you keep up both? FQHCs and RHCs will need to determine how they will approach this situation. With G0511 being revalued down a small amount to incorporate the new codes, providing unbillable services may not be financially practical. At the same time, this means that FQHCs can receive higher reimbursement than other clinics for solely capturing device measurements without any care management time spent.

CMS reaffirms other existing RPM/RTM rules

This is where the unusual facet of the proposed rule comes in. CMS took the opportunity to summarize some of the current rules for remote monitoring services. Among them:

• With the end of the COVID-19 public health emergency (PHE), RPM services must, once again, only be furnished to established patients, with established patients including those who received initial remote monitoring services during the PHE.
• The end of the PHE ended the permissible use of the temporary 2-day RPM billing requirement for patients with a suspected or confirmed diagnosis of COVID-19. The 16-day requirement is, once again, the requirement for billing remote monitoring services for all patients.
• Only a single practitioner can bill RPM CPT codes 99453 and 99454, or RTM CPT codes 98976, 98977, 98980, and 98981, during a 30-day period, and only when at least 16 days of data have been collected on at least one medical device.
• When patients are provided and using multiple medical devices, services associated with all these medical devices can only be billed once per patient per 30-day period.

Why did CMS feel the need to spell out so many existing rules? As the agency stated in the proposed rule, "We have received many questions from interested parties about billing scenarios and requests for clarifications on the appropriate use of these codes in general. We believe it is important to share with all interested parties a restatement clarification of certain policies."

What Does It Mean?

It will be interesting to see what changes in this proposed rule are finalized and what undergoes revision or is shelved. Standalone reimbursement for RPM and RTM services when provided by FQHCs and RHCs would be a long-awaited win for a patient population particularly well-suited for remote monitoring.

Unfortunately, CMS seems to be holding firm on its contention that 16 days of data should be monitored for certain RPM and RTM codes to be billed — despite evidence that fewer days of data transmissions can improve patient outcomes.

CMS will accept comments on the proposed rule through Sept. 11, 2023. If you have strong feelings on any of these proposed changes to remote patient monitoring or the several other remote care management-related proposed changes, I encourage you to share your thoughts with CMS. They, as well as Medicare administrative contractors, have shown a willingness to consider the feedback of subject matter experts when making decisions on the future of remote care management.

Daniel Tashnek is the co-founder of Prevounce Health, a healthcare software company that simplifies the provision of preventive medical services, chronic care management and remote patient management. Daniel is also a practicing healthcare attorney specializing in regulatory compliance, reimbursement, scope of practice, and patient care issues.