CMS issued corrections on January 19 to the 2021 Physician Fee Schedule, clarifying how healthcare providers are paid for remote patient monitoring (RPM) and opening the door to improved reimbursement. The coverage was changed due to industry criticism following the December 2020 release of the final rule.
Originally, in order to qualify for reimbursement under CPT billing codes 99457 and 99458, CMS mandated at least 20 minutes of interactive communication time between provider and patient over a calendar month, but that interactive communication couldn’t be part of the 20 minutes of RPM care. The January 19 ruling now states that “interactive communication” can include both in-person and connected health channels.
Here is the National Law Review‘s summary of the changes:
20 minutes includes, but is not limited to, “interactive communication” with the patient
The required 20 minutes of time associated with CPT codes 99457 and 99458 includes care management services, as well as synchronous, real-time interactions with the patient. CMS clarified the “interactive communication” element contributes to the total time, but is not the only activity that can be included when calculating the 20 minutes per month. Put another way, the 20-minutes of intra-service work associated with CPT codes 99457 and 99458 includes a practitioner’s time engaged in “interactive communication” as well as time engaged in non-face-to-face care management services during the month.
RPM billing codes by one practitioner, per patient, per period
Only one practitioner can bill RPM CPT codes 99453 and 99454 during a 30-day period and only when at least 16 days of data have been collected on at least one medical device. “Even when multiple medical devices are provided to a patient,” CMS explained, “the services associated with all the medical devices can be billed by only one practitioner, only once per patient, per 30-day period, and only when at least 16 days of data have been collected.” Of course, the services must also be reasonable and necessary in order to be reimbursed under the Medicare Program.
Know your remote monitoring codes
CMS reminded practitioners the universe of RPM-related billing codes is not limited to just CPT codes 99091, 99453, 99454, 94557, and 99458. There are additional, more specific codes available for billing that allow remote monitoring (for example, CPT code 95250 for continuous glucose monitoring and CPT codes 99473 and 99474 for self-measured blood pressure monitoring). When a more specific code is available to describe a service, the CPT Handbook dictates that the more specific code should be billed. Remote monitoring can often have two facets. The first part is collecting and monitoring the data, whereas the second part is treatment/ management services of the conditions monitored with the data. Practitioners should consult with their certified billing and coding professionals to help ensure accurate coding and claim submission.
All in all, this is good news for RPM providers, as RPM is becoming an increasingly popular and effective way to monitor patients from their home.