Remote Monitoring in Primary Care: Key takeaways from CMS physician 2021 RPM fee schedule

In an update on Jan 19, 2021 in the Federal Register, the Centers for Medicare & Medicaid Services has amended the 2021 Physician Fee Schedule to clarify reimbursement for remote patient monitoring programs.

We’ve pulled out 7 takeaways from a post by Foley and Gartner, that would be meaningful to providers looking to use RPM for primary prevention.

1. Revised Definition of “Interactive Communication”

CMS clarified that the 20 minutes of time associated with 99457 and 99458 “should include care management services and synchronous, real-time interactions.” This clarified that interactive communication contributes to the total time, but is not the only activity that should be included in the total time. The document reaffirms that at least some of the time for each code needs to be “interactive communication,” but it leaves no exact stipulation as to the proportion of time spent between review of the monthly remote monitoring patient data report and the “interactive communication” component.

2. Clarification Concerning Device Requirements

The final rule clarified uncertainties surrounding the types of devices supplied to patients as part of CPT 99454. Of note, CMS stated that such devices must meet the definition of a medical device per the Food, Drug, and Cosmetic Act and electronically (i.e., automatically) collect and transmit a patient’s physiologic data rather than permit patients to self-report or self-collect data.

3. Reinstall Patient Status Requirement

CMS finalized that it will re-implement the requirement that an established patient-physician relationship exist for the furnishing of RPM following the end of the COVID-19 public health emergency.  For providers practicing in the medical home model, with established panels of patients at risk for obesity, diabetes and hypertension, this provides an opportune moment to implement a proactive population health strategy to improve patient outcomes.

4. Permitted Consent Obtainable at Time of Service

CMS has finalized the rule permitting providers to obtain patient consent to receive RPM services when services are initially furnished rather than in advance.

 5. Approved furnishing of services by auxiliary personnel

CMS established a permanent policy that allows auxiliary personnel to furnish CPT 99453 and 99454 services under a physician’s supervision. CMS has previously defined auxiliary personnel to mean “… any individual who is acting under the supervision of a physician, regardless of whether the individual is an employee, leased employee, or independent contractor of the physician, or of the legal entity that employs or contracts with the physician.”  This gives flexibility to providers in terms of how remote monitoring services are provided and allows the provider to be a third party independent contractor outside of that provider’s physical office.

6. Clarification of Billing for Services for RPM 

In the correction document, the agency clarified its position that only a single practitioner can bill 99453 and 99454 during a 30-day period. This clarification runs counter to the enforcement and prior general understanding of the RPM codes and may warrant questioning the patient if they are already receiving RPM services from another practitioner during enrollment.  At PreventScripts we foresee an emerging turf war as multiple stakeholders will want to provide RPM services to patients.  If you stratify patients by disease-state needs, you have primary, secondary and tertiary panels of patients. RPM can serve all of these. As noted above, mostly RPM has been serving secondary  and tertiary cases to date. But primary care providers have an opportunity to leverage their role in the healthcare system and provide RPM to upstream patients while specialists focus on remote monitoring initiatives for secondary and tertiary disease prevention. 

 7. Reestablishing 16 measurement-days to bill

CMS confirmed that it will maintain the existing requirement that 16 days of data for each 30- day period must be collected and transmitted in order to bill CPT 99453 and 99454.

The evolution of RPM is an exciting development for patients. The majority of use cases for RPM now are focused around reducing hospital readmissions and managing intensive chronic care patients.  Primary Care-based Remote Monitoring is an important weapon in the arsenal of value based care and an important component of a forward thinking quality improvement strategy.  RPM for upstream conditions such as metabolic syndrome, pre-diabetes, Stage One Hypertension, and obesity present opportunities for intervention BEFORE our populations are on the downward spiral into lifelong pharmaceuticals that come wrought with attendant side effects, specialist visits, and expensive hospital care. We know there will always be those patients who need the secondary and tertiary levels of care. But, with 88 million people walking around with pre-diabetes, we also know there are plenty of patients who could benefit from efforts to delay or prevent onset of disease before they even start. RPM is one way to accomplish this.