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With changed reimbursement restrictions come RPM opportunities

Posted by GetWellNetwork on April 27, 2020
GetWellNetwork

There has been a lot of hype about remote physiologic monitoring (RPM), colloquially known as remote patient monitoring, in recent years. These services are beneficial for patients and providers alike, allowing patients to receive the personal-touch care they need from a distance, while providing additional revenue streams for providers and enabling them to easily scale resources for follow-up communication.

With the COVID-19 public health emergency, hospitals and health systems are strapped for resources, both in terms of reduced revenue and increased patient demand. 

These healthcare organizations are working diligently to shift their businesses to a remote model to help reach patients in quarantine, self-isolation and other forms of physical distancing. At the same time, however, they’re losing revenue from those same patients, who no longer want to (or are able to) come in for appointments and elective surgeries.

Just because patients aren’t coming into a brick-and-mortar hospital doesn’t mean that providers have ceased working, and it’s important that these providers be reimbursed for this work. And the Centers for Medicare & Medicaid Services (CMS) has made it easier than ever to do so.

Due to recently changed restrictions announced by CMS, it’s time to consider whether remote physiologic monitoring could be used to help patients during the COVID-19 public health emergency.

What is remote physiologic monitoring?

Remote physiologic monitoring allows for the collection and interpretation of physiologic data, as well as treatment management services, all offered remotely.

This is good news in the era of the novel coronavirus: As the Centers for Disease Control and Prevention (CDC) states, “most people with COVID-19 have mild illness and can recover at home without medical care.” At the same time, however, the Advisory Board writes that COVID-19 has an asymptomatic window of up to five days. 

Therefore, treatment of COVID-19 is both well-suited for remote care and brings with it potential exposure risks for providers and patients who are seen in-person, making a remote monitoring option all the more urgent.

Given all of these factors, CMS recently took a closer look at remote physiologic monitoring, and finalized new changes on an interim basis. CMS stated that they “believe that RPM services support the CDC’s goal of reducing human exposure to the novel coronavirus while also increasing access to care and improving patient outcomes.”

What are some of the CMS reimbursement codes for RPM?

We’ll touch on four primary codes that can be used for reimbursement, those which enable communication monitoring.

  • The first, 99453, is the code a healthcare organization can bill for once at the point of enrollment, and covers activities such as initial enrollment, activation, education and set up.

In conjunction with 99453, organizations can use either code 99091 or codes 99457 and 99458, but not both. Both of these codes enable organizations to bill for RPM services, but which code to use depends on how long the service has been provided for and who has interacted with the patient. 

Let’s break those codes down further:

99091

  • This allows for physicians or qualified healthcare professionals to review patient physiological data. 
  • For this code, review of patient physiologic data must be completed by physicians or qualified health care professionals (QHCP) and 30 minutes of time must be spent per 30-day period. 

99457 and 99458

  • This allows for collection of identical patient physiological data, but unlike 99091, does require interactive communication between the patient and caregiver. 
  • The caregiver does not have to be a qualified healthcare professional, however, as is required for code 99091; for code 99457, clinical staff can also review and communicate with patients. 
  • This code requires 20 minutes of time spent per calendar month; providers who go over can claim reimbursement under the sister code 99458.

What specific changes have been made to the CMS reimbursement codes for RPM?

So far, the criteria outlined are the same as they’ve been in the past. However, with the advent of the COVID-19 pandemic, CMS has recently made some impactful changes to the RPM codes, opening the door for monitoring of millions of patients, and for tandem reimbursement for providers who choose to put these technologies into practice. 

Here are the changes that were recently made by CMS that impact remote patient monitoring and management: 

  1. Traditionally, as a communication technology-based service (CTBS), RPM has only been furnished to established patients, as a condition of reimbursement. CMS, concerned this “could be an obstacle to delivery of reasonable and necessary care particularly during current conditions,” is now allowing RPM services to be provided to new patients, in addition to established patients.

  2. Patients were previously responsible for copays when utilizing RPM technology. With the advent of the COVID-19 pandemic, patient copays can now be waived for RPM services during the “national health crisis.” (Note: It is the provider’s option to waive copays or not.)

  3. Previously, verbal consent for RPM services for a Medicare beneficiary had to be obtained in-person every time RPM was ordered. Much like the driver behind the expansion from established patients to all patients, CMS harbored concerns that the current COVID-19 pandemic would make it difficult to acquire patient consent, interfering with the provision of beneficial RPM services. Now, consent only needs to be obtained once annually.

  4. Review of patient physiological data traditionally has only been reimbursed if collected from chronic patients (e.g., A1C data, weight, and other metrics for diabetics). Now, both chronic and acute patients may take advantage of remote physiologic monitoring. This means that a patient with an acute respiratory virus (like the novel coronavirus) can use pulse oximetry to monitor metrics like pulse or oxygen saturation levels, even if they’ve never had a chronic condition in the past. 

Note: all changes have been finalized on an interim basis.

The bottom line

Remote physiologic monitoring, also known as remote patient monitoring, holds great promise for keeping patients and providers connected and healthy even while remote, particularly during a public health emergency like the COVID-19 pandemic. With the recently relaxed restrictions around reimbursement codes, made by CMS, there’s never been a better time to assess how your organization might best use this technology.