CMS has
issued its final update to the 2019 Physician Fee Schedule and Quality Payment
Program, including three new CPT codes for reimbursement of remote patient
monitoring. The changes mark an important step in the government's acceptance
of mHealth and telehealth technology.
November 02,
2018 - The Centers for Medicare & Medicaid Services has finalized
plans to reimburse healthcare providers for certain remote patient monitoring
and telehealth services.
CMS this week issued
its final 2019 Physician Fee Schedule and Quality Payment
Program, opening the door to reimbursement for connected care
services that enable providers to manage and coordinate care at home. The
changes are focused on three new CPT codes that separate RPM services from
telehealth, which is more restricted.
“This provides
opportunities for patients around communicating with providers remotely,” CMS
Administrator Seema Verma said during a Thursday afternoon conference call with
reporters. “We’ve never had this in the program at large. There has been a
telehealth benefit mostly for rural providers, but access to care is not just a
rural issue, it’s something that patients struggle with across the country.”
“This is an historic
change in terms of increasing access and it’s also a great example of some of
the efforts that we’re trying to make around supporting innovation,” she added.
“This has been happening in the private market and I think the opportunities
and the impact could be tremendous. We’re excited to be able to harness this
innovation for Medicare beneficiaries.”
Alongside the
2,378-page rule, CMS also issued a fact sheet breaking
down the changes.
When the changes were
proposed this past July, Nathaniel Lacktman, a partner and healthcare lawyer
with Foley & Lardner who chairs the firm’s Telemedicine Industry Team and
co-chairs its Digital Health Work Group, said they represent a “landmark change” in
government efforts to embrace telehealth and mHealth.
He made that point
again in a blog released today.
“With
the new CPT codes for Chronic Care Remote Physiologic
Monitoring, RPM will become an area of significant upside potential
over the coming years,” Lacktman said. “Hospitals and providers
using RPM and non-face-to-face technologies to develop patient
population health and care coordination services should take a serious look
at these new codes, and keep abreast of developments that can drive recurring
revenue and improve the patient care experience.”
The new CPT codes
are:
- CPT code 99453: “Remote
monitoring of physiologic parameter(s) (eg, weight, blood pressure,
pulse oximetry, respiratory flow rate), initial; set-up and patient
education on use of equipment.”
- CPT code 99454: “Remote
monitoring of physiologic parameter(s) (eg, weight, blood pressure,
pulse oximetry, respiratory flow rate), initial; device(s) supply with
daily recording(s) or programmed alert(s) transmission, each 30
days.”
- CPT code 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.”
Among the significant
changes highlighted by Lacktman, CPT 99457 allows RPM services to be performed
not only by the physician or qualified healthcare professional, but also by
“clinical staff,” such as RNs and medical assistants. This could make it easier
for healthcare providers to figure RPM programs into their workflow.
Lacktman also noted
the new guidelines aren’t specific about the technology that would qualify for
reimbursement.
“Many advocates asked
CMS to clarify the kinds of technology covered under CPT codes 99453, 99454,
and 99457,” he wrote in his blog. “Some groups gave examples of the kinds
of technology they believe these codes should cover, such as software applications
that could be integrated into a beneficiary’s smartphone, Holter-Monitors,
Fitbits, or artificial intelligence messaging. Other examples
included behavioral health data and data from wellness applications, or
results of patients’ self-care tasks. Unfortunately, CMS did not
offer any specifics in the final rule on what technology qualifies, but CMS
does plan to issue forthcoming guidance to help inform practitioners and
stakeholders on these issues. This may likely be in the form of a CMS MLN
article or Q&A.”
Aside from the new
CPT codes, CMS has issued an interim final rule to eliminate geographic
restrictions for telehealth services furnished for purposes of treatment of a
substance use disorder or a co-occurring mental health disorder for services
furnished on or after July 1, 2019. That ruling - a provision from
the Substance Use-Disorder Prevention that Promotes Opioid
Recovery and Treatment (SUPPORT) for Patients and Communities Act –
would also make the home an originating site, enabling consumers to receive
treatment through telehealth at home.
Also this week, CMS
released final calendar year 2019 and 2020 payment and policy
changes for Home Health Agencies and Home Infusion Therapy Suppliers.
Among the changes listed, CMS will no longer require the home health agency to
prove medical necessity for a home visit in place of an office visit, giving
HHAs more leeway to use RPM and telehealth.
“CMS is finalizing
its proposal to define remote patient monitoring in regulation for the Medicare
home health benefit and to include the cost of remote patient monitoring as an
allowable cost on the HHA cost report,” the agency said. “Studies note that
remote patient monitoring has a positive impact on patients as it allows
patients to share more live-time data with their providers and caregivers,
which will lead to more tailored care and better health outcomes. CMS believes
that defining remote patient monitoring and including such costs as allowable
costs on the HHA cost report could encourage more HHAs to adopt the
technology.”
These announcements
follow by one week a CMS proposal to expand the use of
telehealth and telemedicine in Medicare Advantage plans.
As part of a
362-page proposal issued on October 26, the Centers for Medicare &
Medicaid Services (CMS) is proposing to eliminate geographical restrictions on
telehealth access in MA plans by 2020, enabling those in urban areas to use
connected health technology. The proposal would also give members more
locations to access care, including their own home.
“The Original
Medicare telehealth benefit is narrowly defined and includes restrictions on
where beneficiaries receiving care via telehealth can be located,” the agency
wrote in an
accompanying fact sheet. “CMS believes that the additional
telehealth benefits in MA will increase access to patient-centered care by
giving enrollees more control to determine when, where, and how they access
benefits.”
“The proposed rule
would give MA plans more flexibility to offer telehealth benefits to all their
enrollees, whether they live in rural or urban areas,” the agency stated. “It
would also allow greater ability for Medicare Advantage enrollees to receive
telehealth from places including their homes, rather than requiring them to go
to a health care facility to receive telehealth services. Plans would also have
greater flexibility to offer clinically-appropriate telehealth benefits that
are not otherwise available to Medicare beneficiaries.”
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