The Centers for Medicare & Medicaid Services (CMS) has issued its proposed 2025 physician fee schedule (PFS) rule. It includes many revisions and additions that could significantly affect the billing, coding, and delivery of remote care management. This includes potentially substantial rule changes impacting remote patient monitoring (RPM), chronic care management (CCM), federally qualified health centers (FQHCs), and preventive services.
We'll be taking a deep dive into these and the other remote care management changes and additions you should know about in a special webinar on July 30 at 2:00 PM EDT. Register here. If you can't make the webinar, we encourage you to still sign up as all registrants will receive a recording of the program.
8 Noteworthy Changes Under Consideration
While we're still assessing the 2,200-plus page proposed rule, a number of changes under consideration already stand out. Here are 8 topics we'll be covering more extensively in our webinar.
Major overhaul of the recent RPM and CCM expansion for FQHCs.
CMS is proposing splitting HCPCS code G0511 — used by federally qualified health centers (FQHCs) and rural health clinics (RHCs) — into distinct payments based on the care management service rendered. G0511 has been used as a catch-all code for numerous services, including CCM and RPM. The 2024 PFS final rule included RPM and remote therapeutic monitoring (RTM) in HCPCS G0511. If enacted, this could significantly expand the flexibility and number of reimbursable services for FQHCs and RHCs with care management and remote monitoring programs.
Audio-only telehealth waiver expansion.
CMS is proposing to permit the use of audio-only communication — instead of requiring video — to satisfy the interactive communication requirement for telehealth visits.
Big news for virtual direct supervision.
CMS is proposing to permanently allow virtual direct supervision for some services with established patients and extended virtual direct supervision for all services through the end of 2025.
Overhaul of care management for advanced primary care offices.
CMS is proposing to create new codes and payments for advanced primary care management services (APCM). Three new HCPCS G-codes would bundle elements of several existing care management and communication technology-based services. The bundles would reflect the essential elements of the delivery of advanced primary care, including CCM, principal care management, and transitional care management.
Introduction of caregiver training services (CTS) codes.
CMS is proposing to establish new coding and reimbursement for caregiver training for direct care services and supports. Topics of trainings could include infection control, medication administration, wound dressing changes, special diet preparation, and medication administration. CMS is also proposing to establish new coding and reimbursement for caregiver behavior management and modification training that could be furnished to the caregiver(s) of an individual patient. These CTS services could be provided via telehealth.
New billing opportunity for G2211.
CMS is proposing to permit billing the HCPCS add-on code G2211 alongside an evaluation and management (E/M) visit on the same day as an annual wellness visit, vaccine administration, or any Medicare part B preventive service.
Expand colorectal cancer screening coverage.
This preventive service may receive a big update and expansion, which could help strengthen access for rural communities, among others.
RTM payment cut.
CMS is proposing to cut reimbursement RTM. While noteworthy, what's important to know is that CMS is not proposing cuts to RPM reimbursement. RTM is in its infancy, with adoption remaining low for now.
Special 2025 PFS Proposed Rule Webinar: Join Us July 30
If your organization provides or is considering delivering remote care management or annual wellness visits with preventive services, CMS is considering a lot of big changes that you will want to know about. Get more information on the proposals noted above and the steps you should consider taking in anticipation of proposed changes becoming finalized during our special webinar, "Understanding Medicare's 2025 Proposed Changes to Remote Care Management," on July 30 at 2:00 PM EDT. Sign up for this special program today!
