Available on-demand webinar: Building Successful FQHC and RHC Remote Patient Monitoring Programs
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The 2024 Medicare Physician Fee Schedule (PFS) final rule included news of great interest to federally qualified health centers (FQHCs) and rural health clinics (RHCs), with perhaps no developments bigger than CMS finalizing its policy to reimburse FQHCs and RHCs for remote patient monitoring and remote therapeutic monitoring services.
FQHCs and RHCs, sometimes referred to as rural health centers, now have the opportunity to launch remote patient monitoring/remote therapeutic monitoring programs that provide more comprehensive remote care management services to patients and generate significant, sustainable, and growable revenue. Here are highlights from the PFS final rule.
For FQHCs and RCHs contemplating whether to proceed with developing remote patient monitoring (RPM) and remote therapeutic monitoring (RTM) programs, here are 10 things to know.
1. CMS extends RPM and RTM coverage to FQHCs and RHCs
Historically, remote patient monitoring (i.e., remote physiologic monitoring) and remote therapeutic monitoring codes had not been separately billable by FQHCs and RHCs, with CMS considering RPM and RTM "included" within an all-inclusive rate. In 2019, CMS split chronic care management (CCM) out from the "all-inclusive" general care management code (HCPCS G0511), thus allowing FQHCs and RHCs to bill for CCM under this HCPCS code. Yet, CMS chose not to split RPM out at the time (RTM was still a few years away from becoming a clearly defined and covered service).
This changes with the 2024 PFS final rule, with CMS including RPM and RTM in HCPCS G0511. The inclusion has been long advocated for, and it's terrific to see it finally happen.
2. List of services covered under HCPCS G0511 expanded further
When appropriate, FQHCs and RHCs can now bill HCPCS G0511 for remote patient monitoring, remote therapeutic monitoring, chronic care management, and the following:
- Principal care management (PCM)
- Behavioral health integration (BHI)
- Chronic pain management (CPM)
- Community health integration (CHI)
- Principal illness navigation (PIN)
Note: The latter two services are new for 2024, having been finalized in the 2024 PFS final rule. Community health integration (CHI) services focus on addressing the social determinants of health (SDOH) needs interfering with diagnosis or treatment of a patient's problems addressed in the CHI initiating visit, while principal illness navigation (PIN) services can be furnished following an initiating provider visit to establish or affirm a treatment plan for at least one serious, high-risk condition expected to last longer than 3 months.
3. CCM reimbursement rates lowered, but billing opportunities significantly increased
For 2024, CMS changed the methodology it uses to calculate the payment rate for HCPCS G0511 that takes into account the usage frequency of the various services covered under G0511. The revised methodology used to calculate the reimbursement rate for G0511 resulted in a slight payment reduction for 2024, but the decrease is less than what would have resulted from the formula normally used to calculate reimbursement adjustments. Base reimbursement went from about $78 in 2023 to $73 in 2024.
What does this mean? Federally qualified health centers and rural health clinics with pure CCM programs will generate lower payments per service in 2024 than they did in 2023. However, FQHCs and RHCs that expand their programs to include an additional service like remote patient monitoring can generate higher revenue. The expanded and improved access for patients and increased billing opportunities helps reduce the sting of the reimbursement cut.
4. Some FQHC and RHC coverage and reimbursement uncertainty remains
The 2024 PFS final rule left us with some questions that will hopefully be answered soon about coverage for RPM and RTM. We know FQHC and RHC billing for the base monthly RPM service (i.e., remote monitoring and management of device readings) together with monthly CCM service (i.e., up to 60 minutes of clinical staff time providing care management services) is acceptable.
For example, a patient with two or more chronic conditions, like hypertension and obesity, could be enrolled in a "dual" RPM and CCM program. The FQHC or RHC could provide the patient with an at-home blood pressure monitor, create a comprehensive care plan, and offer ongoing care management support. If at least 16 device readings are collected and at least 20 minutes of staff time is spent helping patients achieve care plan goals, the FQHC or RHC could bill HCPCS G0511 twice for that patient each month. When you combine the $73 in RPM reimbursement for the device readings and $73 in reimbursement for CCM, it equals $146 in expected monthly reimbursement, as represented in the following graphic:
A key outstanding question is whether FQHCs and RHCs will be able to bill HCPCS G0511 a third time for initial enrollment into a remote patient monitoring program. Under CPT code rules, practices can bill a one-time code tied to setting up the patient with their RPM device for the first month they collect 16 readings. Were the same logic to apply to FQHCs and RHCs, a health center could bill G0511 three times for a single patient in the first month: device setup, 16 readings, and 20-plus minutes of care management. This would total $219 in reimbursement, as represented by the graphic that follows. G0511 would be billed twice in months thereafter.
We expect CMS to offer clarification as to whether initial device setup is separately billable or whether they consider it to be bundled with the 16 device readings. In either scenario, a dual RPM and CCM program can offer meaningful, recurring revenue.
5. RPM and RTM is of significant value for FQHC and RHC patients
While patients nationwide are benefiting from remote patient monitoring and remote therapeutic monitoring, expanding access to these services through FQHCs and RHCs is a big win for patient care and improving patient outcomes. We know that FQHC and RHC patient demographics include higher prevalence of chronic conditions and underserved populations, with individuals facing entrenched barriers to patient care, such as low mobility, the need to travel longer distances to receive care, and higher levels of indigency.
FQHCs and RHCs are particularly well suited for care management because of their integrated care model and high focus on social determinants of health (SDOH). Patient engagement and buy-in is crucial for the success of RPM and RTM, and FQHCs and RHCs tend to excel in these areas.
6. Delivering RPM and RTM services is fairly straightforward
The core Medicare rules FQHCs and RHCs will need to comply with when they launch remote patient monitoring and remote therapeutic monitoring programs are easy to follow. Medicare gives providers great flexibility in choosing which conditions and patient cohorts utilize RPM. An FQHC or RHC would need to identify the condition(s) they would like to manage remotely and launch the program to offer the service to its patients. Medicare RTM coverage is similar but is restricted to specific condition types or modalities (e.g., respiratory system status, therapy response).
Following enrollment in either program, a patient will need to be provided with a device to collect the physiological or therapeutic data. RPM and RTM devices must be electronically connected. Depending on an FQHCs and RHC's device vendor partner, it may be possible to have devices mailed directly to patients. FQHCs and RHCs can also choose to have patients pick up their RPM or RTM devices at the organization's physical location.
Once the device is set up, health data is captured by the device and transmitted from patient to FQHC or RHC electronically. The FQHC or RHC then analyzes this data and gives the patient health and wellness guidance and interventions based upon the results.
7. Common examples of remote patient monitoring applications
Remote patient monitoring can be used to support patients with various chronic conditions. Some of the most common patient applications for RPM include:
- Hypertension management
- Weight measurement for congestive heart failure
- Weight measurement for obesity
- Chronic obstructive pulmonary disease (COPD) management
- Asthma management
- Glucose monitoring/continuous glucose monitoring (CGM)
8. Many choices of RPM devices, with important connectivity considerations
FQHCs and RHCs have choices for what RPM devices they provide to patients to collect health data. The most common RPM devices are blood pressure monitors, weight scales, blood glucose meters, and spirometers, with other device types seeing increased use including pulse oximeters and ECG machines.
One of the most significant decisions FQHCs and RHCs will need to make concerning devices is whether the devices provided to their patients use cellular or Bluetooth technology. A cellular device — with an embedded cellular modem — is typically simple to set up and use, only requiring patients to insert batteries, turn the device on, and then follow the directions for how to operate the device to capture readings (e.g., stepping on a scale). A Bluetooth device requires the completion of more steps, which may include downloading and installing a smartphone app, connecting the device to the smartphone, and ensuring the smartphone can access Wi-Fi.
Using Bluetooth devices may be more challenging for FQHC and RHCs patients who lack access to or cannot afford broadband internet or who are unable to afford newer smartphone models that may be required to run some device apps. Note: Learn more about the differences between cellular and Bluetooth RPM devices here.
9. Patient education is essential
To ensure the short- and long-term viability of a remote patient monitoring or remote therapeutic monitoring program, FQHCs and RHCs will need patients to initially agree with a recommendation that they begin to use an RPM or RTM device (i.e., consent to receiving RPM/RTM services) and then remain engaged and continue to use the device over time. There are a few steps federally qualified health centers and rural health clinics can take to help with patient education and engagement, including:
- Defining RPM or RTM so your patient population understands the service
- Describing how RPM or RTM works
- Explaining the health, wellness, and financial value/benefits of RPM or RTM to your patient population
- Providing instructions on device setup and ongoing usage
- Delivering education using the communication channels patients prefer (e.g., text messaging, phone calls, patient portal, in-person)
- Reengaging with RPM or RTM program participants to answer any questions and ensure they feel continually supported
- Strengthening education and engagement efforts by learning from patient experiences (e.g., surveys of active program participants, evaluating why patients stopped participating, getting feedback from supporting staff)
10. Don't underestimate the importance of choosing a remote patient monitoring system
FQHCs and RHCs have options for the remote patient monitoring and remote therapeutic monitoring system — comprised of software and connected patient devices — they want to use. Making an informed decision on which of the RPM solutions to invest in may prove the difference between an RPM or RTM program that meets patient and program needs or becomes one the organization regrets.
Among the qualities FQHCs and RHCs should prioritize in an RPM/RTM system include the following:
- Ability to support the equipment that will collect and interpret their most pertinent patient data
- Ability to scale as an RPM or RTM program grows
- Ease of system setup and usage, customization options, and availability of training and support provided by the system's vendor
- Ability for the RPM technology to successfully integrate with existing technology, such as an electronic health records (EHR) platform
- Device considerations, including requirements to use a vendor's devices or "bring your own" provided by a different vendor; ability to have devices shipped directly to patients; whether the vendor provides support for patient setup and use of the equipment; and ability to use cellularly connected devices, Bluetooth devices, or a combination of both
- Support for coding and billing of RPM and RTM services, including how the system helps streamline these processes; better ensures clean claims that lead to timely, accurate reimbursements; and empowers compliance with billing requirements
- Priority on security and compliance, which are essential for long-term program viability
Prevounce: The Complete Remote Patient Monitoring System
With a better understanding of remote patient monitoring and remote therapeutic monitoring, including their substantial value for patients and providers, FQHCs and RHCs can take the next step in launching their RPM and RTM programs with confidence. Prevounce is the developer of one of the most trusted, comprehensive remote patient monitoring platforms that includes software and optional connected devices.
Every day, Prevounce is helping organizations, including FQHCs and RHCs, expand patient care outside their walls, bringing the value of remote care management to more people who will benefit from the services. To learn how Prevounce can help your FQHC and RHC establish and build a thriving RPM or RTM program, book a meeting with us here.