The 2021 Medicare Physician Fee Schedule for Remote Physiologic Monitoring

What you should know

During the COVID-19 public health emergency (PHE), CMS loosened regulations on remote physiologic monitoring (RPM) and telehealth in order to increase access to healthcare services. 

In August, CMS released its proposed rule to update the Medicare Physician Fee Schedule (PFS) for calendar year 2021. The proposed rule is one of several proposed rules that reflect a broader Administration-wide strategy to create a healthcare system that results in better accessibility, quality, affordability, empowerment, and innovation.1

Proposed Clarifications for RPM 

RPM devices
CMS will require that the medical device(s) used for RPM must be a medical device as defined by Section 201(h) of the Federal Food, Drug, and Cosmetic Act, that the device must be reliable and valid, and that the data must be electronically (i.e., automatically) collected and transmitted rather than self-reported.

    Conditions covered
    Practitioners may furnish RPM services to remotely collect and analyze physiologic data from patients with acute conditions, as well as from patients with chronic conditions.

      who can order & bill
      RPM codes are evaluation and management (E/M) codes and can only be billed by physicians and non-physician practitioners eligible to bill E/M services.

        established relationship
        As long as the public health emergency continues, providers can remotely monitor patients without having first conducted a new patient E/M visit. After the PHE ends, CMS will require that an established patient-physician relationship exist for RPM services to be furnished.

          CMS also proposed permanently adopting two clarifications to RPM services that the agency had implemented under the federally declared PHE:
          Auxiliary personnel
          Allowing both clinical staff and non-clinical employees (auxiliary personnel), including contractors, to provide RPM services within 99453 and 99454 under the billing practitioner’s general supervision.

            consent
            Allowing providers to obtain patients’ consent at the time RPM services are furnished.

            Proposed New Interpretations 

            interactive communication
            CMS stated that for CPT codes 99457 and 99458, an “interactive communication” is a conversation that occurs in real-time and includes synchronous, two-way interactions that can be enhanced with video or other kinds of data as described by HCPCS code G2012.

            The new clarification mandates at least 20 minutes per month of direct patient communication, as opposed to 20 minutes of total RPM service, such as reviewing and analyzing RPM data.

            using multiple devices

            CMS stated the CPT language suggests that even when multiple medical devices are provided to a patient, the services associated with all the medical devices can be billed only once per patient per 30-day period and only when at least 16 days of data have been collected.

            CMS also noted that CPT 99453 can be billed only once per episode of care where an episode of care is defined as “beginning when the remote physiologic monitoring service is initiated and ends with attainment of targeted treatment goals.”2

            1 https://www.cms.gov/newsroom/fact-sheets/proposed-policy-payment-and-quality-provisions-changes-medicare-physician-fee-schedule-calendar-year-4 

            2 https://www.cms.gov/files/document/cms-1734-p-pdf.pdf