By Eric Wicklund, mHealth Intelligence | August 8, 2019
CMS is proposing to tweak reimbursement guidelines for remote patient monitoring in the 2020 Physician Fee Schedule, a move that could open the door to more Medicare coverage for mHealth services.
The Centers for Medicare & Medicaid Services is continuing its slow-but-steady move toward Medicare coverage for remote patient monitoring with two changes in the proposed 2020 Physician Fee Schedule that may open the door to more mHealth reimbursement.
The proposed amendments follow the introduction of three CPT codes in last year’s physician fee schedule for certain – and limited – connected health services. Healthcare providers and telehealth experts hailed the new codes as a step in the right direction for digital health adoption, though many also said they were too cumbersome and small to move the needle.
These new changes may be more substantial.
“The CMS proposed rule advances the ability of RPM services to drive revenue and improve the patient care experience,” Nathaniel M. Lacktman, a partner in the Foley & Lardner law firm and chair of its national Telemedicine & Digital Health Industry Team, said in a blog post.
The changes deal with CPT code 99457, which was introduced this past year to cover “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.”
First, CMS has proposed altering code 99457 to refer to the first 20 minutes for RPM service and adding a new code – 994X0 – to cover additional time spent on the service. As amended, the codes would be:
- CPT code 99457 – “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; initial 20 minutes.”
- CPT code 994X0 – “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 amendment does not address how often the new code can be used or if there is a maximum.
Second, CMS is proposing to expressly allow “incident to” billing of CPT code 99457 under general supervision. When that code was created this past year (alongside CPT codes 99453 and 99454), the agency noted that the services could only be delivered by a physician, and not by “auxiliary personnel incident to a practitioner’s professional services.” In April, CMS issued a technical correction allowing “incident to” billing by auxiliary personnel as long as they are under direct supervision – meaning they are in the same building at the same time.
“Under the proposed rule, RPM services reported with CPT codes 99457 and 994X0 may now be furnished under general supervision rather than the currently required direct supervision,” Lacktman wrote in his blog, which was co-authored by Emily H. Wein, an attorney with Foley & Lardner, and Thomas B. Ferrante, a senior counsel with the firm. “The physician or other qualified healthcare professional supervising the auxiliary personnel need not be the same individual treating the patient more broadly. However, only the supervising physician or other qualified health care professional may bill Medicare for the incident to services.”
“Changing the RPM rules to expressly allow incident to billing of CPT code 99457 under general supervision greatly expands the potential operations and business models associated with RPM services, thereby allowing more patients to enjoy the quality-improving benefits of remote patient monitoring,” the blog concluded.
Public comments on the proposed 2020 Physician Fee Schedule will be accepted up until 5 p.m. on September 27.