The 2021 Physician Schedule – RPM Updates

The 2019 Physician Fee Schedule introduced three new CPT codes (#99453, #99454, and #99457) to enable hospitals and home health agencies to qualify for CMS reimbursements. The CMS’s proposed 2021 Physician Fee Schedule, released in August 2020, adds further clarity to how care providers can use the new CPT codes with the existing ones covering Remote Patient Monitoring ( RPM) services to improve coverage. Care providers must understand them well to ensure successful reimbursements for their services. Here we take a close look at the changes. 

RPM services comprise the collection and analysis of physiologic data from a patient in a home setting to create a care management plan. According to the National Health Council, there are over150 million patients with chronic health condition and RPM services can be an invaluable tool to monitor the health of these patients. Unfortunately, this opportunity to leverage RPM services depends directly on how the CMS provides coverage.

The 2021 Physician fee schedule contains guidelines for billing RPM services delivered under general supervision.

Understanding the Updates

All care providers currently offering RPM services must focus on the five CPT codes

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”

99453: “Remote monitoring of physiologic parameter(s) (e.g, weight, blood pressure, pulse oximetry, respiratory flow rate), initial; set-up and patient education on use of equipment.”

99454: “Device(s) supply with daily recording(s) or programmed alert(s) transmission, each 30 days.”

99457: “Remote physiologic monitoring treatment management services, 20 minutes or more of clinical staff/physician/other qualified healthcare professional time in a calendar month requiring interactive communication with the patient/caregiver during the month.”

99458: “Remote physiologic monitoring treatment management services, clinical staff/physician/other qualified health care professional time in a calendar month requiring interactive communication with the patient/caregiver during the month; additional 20 minutes.”

The tweaks made to the CPT codes affect the following areas of RPM services

New and Established Patients:

In the 2021 Physician Fee Schedule final rule, the CMS clarified that RPM services are limited to established patients only. It then expanded coverage of RPM services to new and established patients due to the outbreak of COVID-19. The expansion was introduced to facilitate the treatment of affected patients through virtual care channels. The need for social distancing was another contributing factor behind the CMS’s decision. Once the pandemic has been mitigated, care providers must ensure if the coverage for new patients has been continued.

Action For Care Providers: RPM services providers should keep watch on this component of coverage. If CMS clarifies in the upcoming final rule that a provider-patient relationship can be established and a patient can be enrolled into an RPM program virtually using telehealth, they can continue to bill for new patients who are added virtually.

Interactive Communications: The CMS’s clarification on “interactive communication” requirement in CPT code 99457 includes spending at least 20 minutes on a video platform or the phone with the patient. However, a typical provider and patient encounter comprises data review and communication as a part of the same encounter.

Action for Care Providers: Care providers must ensure to establish clear demarcations between data gathering and conversation time when communicating with the patient via audio or video. Reimbursements may not be completed without establishing the completion of the 20-minute communication time.

Multiple Devices:

CMS has clarified that providers can only bill once under CPT codes 99453 and 99454 per patient during a 30-day period regardless of the no. of devices a patient uses. Both these codes are not to be reported for a patient more than once during a 30-day period.

Action for Care Providers: Care providers to establish these requirements with patients who require the use of more than one medical device to ensure they receive reimbursements.

Personnel Administering the service:

The CMS clarifies that all auxiliary personnel, in addition to clinical staff, can furnish RPM services described by CPT codes 99453 and 99454 as long as they’re under the general supervision of a billing physician or practitioner.

Action for Care Providers: Auxiliary personnel includes individuals who are not clinical staff but leased or contracted employees of the service provider.

At Nalashaa Healthcare we monitor all HHS regulation closely and keep our online platforms updated with the latest information relevant to care providers.

For more information on the RPM solutions to monitor patients , drop us a line at info@nalashaa.com