The Centers for Medicare & Medicaid Service (CMS) has included numerous proposed changes and additions to remote monitoring and care management in its 2024 physician fee schedule (PFS) proposed rule. We explored the key changes and other important takeaways providers must know about from the proposed rule in a special webinar on July 25 (watch the on-demand recording).
In the proposed rule, CMS has taken an interesting position concerning remote monitoring services — more specifically, remote physiologic monitoring (i.e., remote patient monitoring or RPM) and remote therapeutic monitoring (RTM). The agency has included a few proposed changes. That's typical for a proposed rule.
What's atypical is CMS summarizing some of the current rules for remote monitoring services. The decision by CMS to allocate a portion of the proposed rule to resharing this information was brought about following the submission of many questions concerning proper RPM and RTM coding and billing requirements, notes CMS in the proposed rule.
Read on to get up to speed on the remote monitoring services issues covered in this latest proposed rule.
Two Code Families: RPM and RTM
CMS reiterated that it has established payments for two defined CPT code families describing different types of remote monitoring services: remote physiologic monitoring (RPM) and remote therapy monitoring (RTM). Note: We provide the lists of codes near the end of this post.
Reaffirmations of Current Rules:
General Supervision Rules Apply
CMS reiterated that it has designated the above remote monitoring codes as care management services, meaning its rules for general supervision apply. "General supervision," as defined by Medicare, means a service is delivered or furnished under a physician's overall direction and control but the service does not necessarily require the physician's physical presence during the delivery of service.
CMS reiterated that RTM or RPM services can be billed concurrently with chronic care management (CCM), transitional care management (TCM), principal care management (PCM), chronic pain management (CPM), or behavioral health integration (BHI).
However, practitioners may bill RPM or RTM, but not both RPM and RTM, concurrently with the aforementioned services.
New Vs. Established Patients
During the COVID-19 public health emergency (PHE), CMS removed the requirement that there must be an established patient-practitioner relationship to initiate the delivery of remote patient monitoring services. In the 2024 proposed rule, CMS reiterated that with the end of the PHE, RPM services must once again only be furnished to established patients. Established patients include those who received initial remote monitoring services during the PHE.
16-Day RPM Requirement
Prior to COVID-19, the number of measurement days in a month (i.e., 30 days) required to bill remote monitoring services was straightforward. The minimum number was 16. But a federal waiver issued early in the pandemic added a caveat to this requirement when CMS stated it was permitting providers to deliver and bill for RPM services to patients with suspected or confirmed cases of COVID-19. The waiver stated that during the PHE, CMS would permit reporting of RPM services to Medicare for periods of time of fewer than 16 days but no less than two days. This temporary rule change was commonly referred to as Medicare's "2-day RPM requirement."
What's important to understand is billing for CPT codes 99453 and 99454 requires usage of a device that collects and transmits 16 or more days of data every 30 days for the billing of these codes — i.e., the "16-day RPM requirement."
Some providers and RPM service vendors incorrectly (and one could argue inappropriately, in some instances) applied the 2-day RPM requirement to all patients during the PHE. In early 2021, CMS stated its 2-day RPM requirement should only be applied to patients with a suspected or confirmed diagnosis of COVID-19.
In the 2024 proposed rule, CMS reiterated that with the end of the PHE came the end of the use of the 2-day requirements for patients with a suspected or confirmed diagnosis of COVID-19. The 16-day requirement is once again the requirement for billing remote monitoring services for all patients — more specifically, CPT codes 98976, 98977, 98978, 98980, and 98981.
Single Practitioner Billing
In the new proposed rule, CMS reiterated that only a single practitioner can bill RPM CPT codes 99453 and 99454, or RTM CPT codes 98976, 98977, 98980, and 98981, during a 30-day period (and only when at least 16 days of data have been collected on at least one medical device).
Multiple Medical Devices
CMS reiterated that even when patients are provided and using multiple medical devices, the services associated with all these medical devices can only be billed once per patient per 30-day period.
Proposed 2024 Rule Changes:
Clarifying Concurrent RPM and RTM Billing
In the 2024 proposed rule, CMS is proposing to clarify that RPM and RTM may not be billed together and no time should be counted twice by billing for concurrent RPM and RTM services.
In instances when a patient receives both RPM and RTM services and there may be multiple devices used for monitoring, CMS notes that its existing rules would apply in this situation: services (which must be reasonable and necessary) associated with all medical devices can only be billed by one practitioner; only once per patient, per 30-day period; and only when at least 16 days of data have been collected.
Remote Monitoring During Global Periods for Surgery
CMS is also proposing to clarify rules concerning the use of remote monitoring during global periods for surgery. In circumstances where a beneficiary undergoes a procedure or surgery (and receives related services) covered under a global period payment, CMS is proposing to clarify that remote physiologic monitoring services or remote therapeutic monitoring services — but not both RPM and RTM services concurrently — may be furnished separately to the beneficiary. The practitioner would receive payment for the RTM or RPM services, separate from the global service payment, as long as other requirements for the global service and any other service during the global period are met.
For those beneficiaries receiving services during a global period, a provider may furnish RPM or RTM services — but not both — to the individual beneficiary and the practitioner would receive separate payment, as long as the remote monitoring services are unrelated to the diagnosis for which the global procedure is performed and as long as the purpose of the remote monitoring addresses an episode of care separate and distinct from the episode of care for the global procedure. In other words, remote monitoring services provided are intended to address an underlying condition not linked to the global procedure or service.
Key Takeaways From the 2024 PFS Proposed Rule
If you are interested in learning more about these proposed changes to remote monitoring services, including how they would affect providers if finalized, and other noteworthy, proposed changes to remote care management included in the 2024 PFS proposed rule, don't miss our upcoming, special webinar on July 25 at 2:00 EDT. Learn more and register here.
RPM and RTM CPT Codes
Remote physiologic/patient monitoring
- 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
- 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
- 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; first 20 minutes)
- 99458 — 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; each additional 20 minutes (List separately in addition to code for primary procedure
Remote therapeutic monitoring
- 98975 — Remote therapeutic monitoring (eg, therapy adherence, therapy response); initial set-up and patient education on use of equipment
- 98976 — Remote therapeutic monitoring (eg, therapy adherence, therapy response); device(s) supply with scheduled (eg, daily) recording(s) and/or programmed alert(s) transmission to monitor respiratory system, each 30 days
- 98977 — Remote therapeutic monitoring (eg, therapy adherence, therapy response); device(s) supply with scheduled (eg, daily) recording(s) and/or programmed alert(s) transmission to monitor musculoskeletal system, each 30 days
- 98978 — Remote therapeutic monitoring (eg, therapy adherence, therapy response); device(s) supply with scheduled (eg, daily) recording(s) and/or programmed alert(s) transmission to monitor cognitive behavioral therapy, each 30 days
- 98980 — Remote therapeutic monitoring treatment management services, physician or other qualified health care professional time in a calendar month requiring at least one interactive communication with the patient or caregiver during the calendar month; first 20 minutes
- 98981 — Remote therapeutic monitoring treatment management services, physician or other qualified health care professional time in a calendar month requiring at least one interactive communication with the patient or caregiver during the calendar month; each additional 20 minutes (List separately in addition to code for primary procedure)
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