The American Medical Association (AMA) has announced the agenda for its second quarter 2024 CPT Editorial Panel meeting in May, and it includes discussion on what would be a significant and welcome expansion of remote patient monitoring (RPM) and remote therapeutic monitoring (RTM) CPT codes.
The following are key actions around RPM and RTM that AMA is considering:
- Add a remote patient monitoring device supply CPT code that would cover 2-15 calendar days of collected and transmitted data. AMA would revise existing CPT 99454 to cover 16-30 days.
- Revise CPT 99457 to include 11-20 minutes. This would reduce the amount of time clinical staff must engage in interactive communication with a patient/caregiver during the month for 99457 to be reportable. CPT 99457 currently requires at least 20 minutes.
- Revise CPT 99458 to cover each additional 10 minutes of interactive communication. This would reduce the amount of additional time clinical staff must engage in interactive communication for 99458 to be reportable. CPT 99458 currently requires at least an additional 20 minutes.
- Add multiple remote therapeutic monitoring codes to cover 2-15 calendar days of collected and transmitted data. AMA is weighing the addition of three RTM codes to cover the reporting of respiratory, musculoskeletal, and cognitive behavioral therapy for 2-15 calendar days.
- Revise CPT 98980 to include 11-20 minutes of service. As with the revision to the existing 99457 RPM time code under consideration, this change would reduce the amount of time clinical staff must engage in interactive communication with a patient/caregiver during the month for 98980 to be reportable. If approved, AMA would the revise the 20-minute time component for CPT 98981.
Likelihood of Medicare Implementation
While Medicare is not required to update its coding rules as per AMA's CPT code revisions and additions, the federal agency often does so when the association implements changes. Private payers and health plans can choose not to update to the new codesets, but they rarely deviate from AMA's rules. If AMA makes these additions and revisions, it is unlikely that coverage changes would not go into effect until at least 2025.
It's also possible that AMA will reverse course on whether to consider this expansion and revisions. AMA had indicated it would be considering a full redesign of all RPM CPT codes during its first quarter 2024 CPT Editorial Panel meeting in February but then issued an unexpected notice that the application for the RPM code redesign had been withdrawn. It now appears that this withdrawal was intended to permit AMA to revise the changes it was considering to RPM and RTM codes, which we are now seeing in this latest proposal that will be discussed in May.
What This Means to RPM and RTM Programs
If AMA implements the changes under consideration, and Medicare follows suit, providers of remote patient monitoring (i.e., remote physiologic monitoring) and remote therapeutic monitoring will need to revise how they are coding and billing for RPM and RTM to comply with the new codesets and rules. The same is true for private payers and health plans that modify their coding rules to align with AMA's changes. Providers that use remote care management technology to support coding and billing will want to ensure the software's vendor keeps current with the evolving rules and makes any necessary changes to the software to maintain compliant coding and billing.
In addition, RPM and RTM providers will want to begin coding and billing for patients who report RPM or RTM services for periods of 2-15 days and for interactive communication that initial lasts at least 11 minutes and then for 10-minute additional blocks of time beyond 20 minutes of communication. These new coding and billing opportunities may further enhance the financial value and performance of a remote care management program.
Joining the Conversation
If you are interested in attending the meeting and/or sharing your thoughts with AMA on their RPM and RTM considerations, here's what you need to do:
- To register for the meeting, go here, then click "Register now."
- To submit comments, you must be identified as an "interested party." To apply to participate as an interested party, submit your request through the "Interested Party Portal" by Apr. 18, 2024. The deadline to submit written comments is noon CST on Apr. 25, 2024. Interested parties may have an opportunity to comment live during the meeting.
Prevounce will have representatives attending the CPT Editorial Panel meeting and will share any news that comes out of the meeting on social media.
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Disclaimer
Health economic and reimbursement information provided by Prevounce is gathered from third-party sources and is subject to change without notice as a result of complex and frequently changing laws, regulations, rules, and policies. This information is presented for illustrative purposes only and does not constitute reimbursement or legal advice.
Prevounce encourages providers to submit accurate and appropriate claims for services. It is always the provider’s responsibility to determine medical necessity, the proper site for delivery of any services, and to submit appropriate codes, charges, and modifiers for services rendered. It is also always the provider’s responsibility to understand and comply with Medicare national coverage determinations (NCD), Medicare local coverage determinations (LCD), and any other coverage requirements established by relevant payers which can be updated frequently.
Prevounce recommends that you consult with your payers, reimbursement specialists, and/or legal counsel regarding coding, coverage, and reimbursement matters.
Payer policies will vary and should be verified prior to treatment for limitations on diagnosis, coding, or site of service requirements.
The coding options listed here are commonly used codes and are not intended to be an all- inclusive list. We recommend consulting your relevant manuals for appropriate coding options.
The Health Care Provider (HCP) is solely responsible for selecting the site of service and treatment modalities appropriate for the patient based on medically appropriate needs of that patient and the independent medical judgement of the HCP.
