Understanding Medicare’s Changes to RPM Reimbursement for 2021
Summarized below are key takeaways from the final rule.
Furnishing of Services by Auxiliary Personnel
Auxiliary personnel may provide services described by CPT codes 99453 and 99454 (patient education and RPM device set-up) incident-to the billing practitioner. Auxiliary personnel may include contracted employees, such as Veta Health.
Furnishing of Services Only By Providers
Only physicians and non-physician practitioners who are eligible to furnish E/M services (CPT codes 99453, 99454, 99091, 99457, and 99458) may bill remote patient monitoring services.
Patients With Acute & Chronic Conditions
RPM services may be medically necessary for patients with acute conditions as well as with chronic conditions.
Consent Obtainable at Time of Service
Patient consent to receive RPM services can be obtained at the time that RPM services are furnished rather than prior to services behind provided.
Established Patient Requirement
After the COVID-19 PHE ends, there must be an established patient-physician relationship for RPM services to be furnished.
The medical device supplied to a patient must be a medical device as defined by Section 201(h) of the Federal Food, Drug, and Cosmetic Act and be reliable and valid. Additionally, the data must be electronically (i.e., automatically) collected and transmitted rather than self-reported.
Definition of Interactive Communication
The 20 minutes of time needed to bill for CPT codes 99457 and 99458 can include “time for furnishing care management services as well as for the required interactive communication.” An interactive communication (defined as, “a conversation that occurs in real-time and includes synchronous, two-way interactions that can be enhanced with video or other kinds of data”) remains a requirement for billing these CPT codes.
Required Measurement Days to Bill for RPM
Currently, CMS only requires two days of data collection and transmission each 30 days to bill CPT codes 99453 and 99454. After the COVID-19 PHE ends, 16 days of data each 30 days must be collected and transmitted to meet the requirements to bill these CPT codes.
16 Measurement Day Requirement and Initial Training Code (note: not referenced in the Proposed Rule)
CMS “reviewed the CPT prefatory language” of the two practice expense-only codes (CPT codes 99453 and 99454) and is interpreting the initial training code (CPT 99453) to include the 16 days of data each 30 days requirement that is included in the description of CPT 99454.
CMS states, “This 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.”