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Remote Physiologic Monitoring Reimbursement Update
Information regarding coding, coverage, and payment is provided as a service to our readers. Every effort has been made to ensure accuracy. However, HMP and the author do not represent, guarantee, or warranty that coding, coverage, and payment information is error-free and/or that payment will be received.
The January 2021 Business Briefs column reminded physicians and other qualified healthcare professionals (QHPs) that remote physiologic monitoring (RPM) may be one of the ways to expand their services to patients in various places of service. Since then, this author has received numerous questions pertaining to RPM. Because other physicians/QHPs may have similar questions, this column will review the most frequently asked RPM questions.
After reading this article, click here to take a reimbursement check-up quiz.
Q:
Why do you use the terminology “remote physiologic monitoring”? Other people say “remote patient monitoring.”
A:
As a reimbursement consultant, I am usually sharing coding, coverage, and/or payment information. The codes for RPM were introduced in 2019 and are clearly described as “remote physiologic monitoring,” not “remote patient monitoring.” This is because the RPM service must involve the collection, transmission, and analysis of the patient’s physiologic data, which is then used to develop and manage a specific treatment plan for that patient. Technology exists that remotely monitors patients, but does not collect, transmit, or analyze the patient’s physiologic data. Use of that technology is not eligible for the RPM codes.
Q:
Are there any guidelines about the type of devices that qualify for RPM?
A:
Yes, the CPT®1 codebook states, and the Centers for Medicare and Medicaid Services (CMS) concur, that an RPM device must be a medical device as defined by the FDA in section 201(h) of the Food, Drug, and Cosmetic Act.2 However, this author cannot find any language that states the RPM device must be cleared/registered by the Food and Drug Administration (FDA), although FDA clearance may be appropriate. The RPM device must automatically upload the patient’s physiologic data. In other words, the patient cannot self-record or self-report the data. Like all other services and equipment provided to Medicare beneficiaries, RPM must be reasonable and necessary for the diagnosis or treatment of the patient’s illness or injury or to improve the functioning of a malformed body member.
Q:
Is the physician the only person who can order RPM?
A:
A physician or other qualified healthcare professional (QHP) (e.g., nurse practitioner, physician assistant, or clinical nurse specialist) may order and bill for RPM.
Q:
I am confused because I thought RPM services could only be ordered for patients with chronic conditions, but other physicians in my practice say RPM services can only be ordered for patients with acute conditions. In addition, we cannot agree if RPM can be ordered for new and/or established patients. Will you please provide the correct answers?
A:
This author understands why your practice is confused. When RPM services were introduced in 2019, the CMS only covered RPM for patients with chronic conditions. Then the 2021 Medicare Physician Fee Schedule Final Rule stated that RPM services may be provided to patients with chronic conditions and to patients with acute conditions.
The 2021 Final Rule also clearly states that RPM is only covered for “established patients.” However, the CMS waived the “established patient” restriction during the COVID-19 public health emergency (PHE). When the PHE ends, the CMS will only cover RPM for “established patients.”
Q:
Are physicians/QHPs required to obtain patient consent before providing RPM?
A:
Yes, patient consent must be obtained, but it is acceptable to be obtained at the time the first RPM service is performed. The consent can be obtained by the physician/QHP, clinical staff, auxiliary staff, or individuals under contract with the billing physician/QHP.
Q:
In your January column, you described coding for 3 components of RPM:
• 99453 for set-up of and patient education about the medical device that will remotely monitor the physiologic parameters
• 99454 for supplying the device used for daily recording or programmed alert transmissions
• 99457–99458 for 1) analyzing the physiologic data received via RPM, 2) using the data to manage a patient under a specific treatment plan and, 3) having a live, interactive communication with the patient and caregiver
Must a physician/QHP personally perform all the components?
A:
The 2021 MPFS Final Rule states that 99453 and 99454 may be provided, under general supervision of the billing physician/QHP, by clinical staff or by auxiliary personnel who are employees or leased/contracted employees. However, 99457–99458 can only be furnished by a physician, QHP, or by clinical staff under the general supervision of the physician.
The 2021 MPFS Final Rule also provided a nice RPM surprise when the CMS disagreed with the directions in the CPT® codebook and allowed 99091 to be reported only by physicians/QHPs, in addition to 99457 and 99458, when complex data are collected, and more time is devoted exclusively to data analysis and interpretation.
99091: Collection and interpretation of physiologic data (e.g., ECG, blood pressure, glucose monitoring) digitally stored and/or transmitted by the patient and/or caregiver to the physician or other qualified healthcare professional, qualified by education, training, licensure/regulation (when applicable) requiring a minimum of 30 minutes of time, each 30 days.
NOTE: The CPT® codebook also lists codes that describe specific RPM services, e.g., 95250 for continuous glucose monitoring and 99473/99474 for self-measured blood pressure monitoring. When a more specific code exists to describe an RPM service, the more specific code should be reported, rather than 99453, 99454, 99457–99458, and 99091.
Q:
I am confused about the meaning of “interactive communication” required when reporting 99457–99458.
A:
That is understandable because the American Medical Association and the CMS have provided conflicting, instructions, and the CMS even changed their own instructions. Rather than boring readers with the various historical instructions pertaining to interactive communication, let us focus on the latest instructions that were released by the CMS on January 19, 2021.3 The CMS stated that the 20-minutes of work required for 99457/99458 include the practitioner’s time spent in 1) a real-time synchronous, two-way audio interaction with the patient (that can be enhanced with video or other kinds of data), and in 2) non-face-to-face care management services. Therefore, the practitioner is not required to spend a full 20 minutes speaking with the patient.
Q:
If more than one physician/QHP orders different RPM devices for the same patient, can multiple physicians/QHPs bill for RPM in the same month?
A:
When multiple medical devices are provided to a patient, 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. Therefore, when a physician/QHP is considering ordering RPM for a patient, the physician/QHP should verify if the patient is already using an RPM device provided by a different physician/QHP.
Summary
Several years ago, wound/ulcer management physicians/QHPs had a difficult time envisioning the incorporation of RPM into their “toolboxes.” The detailed questions reviewed above, paint a very “different picture” about the physicians’/QHPs’ level of interest in RPM today. This author predicts that RPM will be in the “toolboxes” of many more wound/ulcer management physicians/QHPs in the coming months and years. Hopefully, these questions and answers will help you successfully adopt RPM into your wound/ulcer management practice.
Kathleen D. Schaum is a founding member of the Today’s Wound Clinic editorial advisory board and oversees a consulting business. She can be reached for consultation and questions by emailing kathleendschaum@bellsouth.net.
1. Current Procedural Terminology 2021. American Medical Association, Chicago, IL 2020. CPT® is a registered trademark of the American Medical Association. Current Procedural Terminology (CPT®) is copyright 2020 American Medical Association. All Rights Reserved. Applicable FARS/DFARS apply.
2. Overview of 2021 Medicare Physician Fee Schedule Final Rule. Last accessed 3/20/2021.
3. January 19, 2021 update to 2021 Medicare Physician Fee Schedule Final Rule. Last accessed 3/20/2021.
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