Proposed Billing and Coding Changes for 2020 and 2021
Remote Patient Monitoring (RPM) has proven to be a game-changer in the medical and psychiatry fields. While this innovation has helped many providers find new ways to connect with their patients, it has also led to the big question of, “Who’s going to pay for all this?”. While the Center for Medicare and Medicaid Services or CMS is often offering to pay for RPM, the question often puts a somber mood on the subject. But fear not, since there is a more than adequate answer.
As 2020 moves forward, CMS has paid for many new CPT codes. These will reimburse providers for types of care they may have already provided to keep their patients in good health and also out of the hospital. They have also opened up new streams of potential revenue to help with the transition into value-based care.
As a provider, the following changes are the most significant to be aware of when it comes to taking advantage of Remote Patient Monitoring (RPM).
Physiologic Monitoring and CPT Codes
Back in January 2019, three brand-new codes went into effect. These have proven to be a fantastic way for providers to take advantage of in their RPM program. Code 99453 code covers the device set-up for episode care and patient education. The following can be billed monthly. Code 99454 covers the cost of the device(s) with daily recordings and even programmed alerts are covered. It covers a device used by a patient which supplies a provider with biometric data along with program alerts and transmissions. Code 99454 should be billed every 30 days. It offers reimbursement for providing patients with a device that has been defined by the FDA. As of now, this code’s definition is relatively broad and may be explained further in the future. Code 99457 covers the first 20-minutes of each calendar month for physiologic monitoring treatment and management services by clinical staff, physicians, or other qualified professionals in healthcare. This also requires interactive communication with a patient or caregiver during the month.
In January 2020, an additional Code 99458 went into effect by CMS. This code covers each additional 20-minutes spent on treatment management services. While there is always the extra time when a healthcare professional spends working with a patient participating in an RPM program, using 99458 with 99457 makes it a more realistic reflection of the care that is given and what is required to manage a successful RPM program. However, providers must bill against 99457 for the first 20-minutes and not report these codes for anything less than 20-minutes.
Supervision Changes for Codes 99457 and 99458
Another meaningful change that came into play at the beginning of 2020 are the codes 99457, and 99458. These have been designated as a care management service by CMS. This means they both can be billed under general supervision rather than by direct supervision of a billing provider. The overall effect is that a physician or other healthcare professional that is supervising RPM services doesn’t have to be located at the same site as the primary clinical staff that is delivering them.
ESRD-related Dialysis and Monthly Remote Patient Monitoring Assessments
One of the most significant changes in 2020 is that any patient with end-stage renal disease or ESRD who is currently on dialysis can now get their monthly assessments directly from their nephrologist via remote patient monitoring at their home. All ESRD-related services are included in all the monthly capitation payment CPT codes. These codes are the following: 90951, 90952, 90954, 90955, 90957, 90958, 90960, 90961.
These include ESRD-related services for any home dialysis per full month from ages two years to elderly in age group codes. This includes monitoring of proper nutrition, growth and development assessment, parent counseling, and various services in CPT codes 90963 – 90970. This removes a lot of inconvenience for patients while enabling their providers to capture additional revenue, possibly.
RPM Supervision: Direct and General Changes
Since January 2020, RPM care will no longer need direct supervision. Instead, auxiliary staff can deliver RPM under general supervision. This means Medicare will no longer require physicians and other healthcare professionals to operate from the same place of work. This gives practitioners more opportunity to outsource RPM program staff, centralize staff from multiple locations, or the whole program altogether.
Additional Guidance for RHCs or Rural Health Clinics and FDHCs or Federally Qualified Health Centers
When it comes to RPM billing for FQHCs and RHCs, these organizations are not eligible for these codes (Qardio MD). These health centers are already included at an all-inclusive rate or FQHC payment. CMS will continue to evaluate these codes for further improvements to make it easier for providers to help their patients and bill accordingly.
Consent of Services Consolidation
In 2020, CMS announced that a single annual consent for remote patient monitoring services, instead of multiple documents will be needed for all remote patient monitoring encounters for the subsequent 12 months. This is excellent news for the patient as it removes any hassles and endless confusion that comes from having to sign more than one form. For providers, it eliminates duplicate and needless paperwork. These codes provide reimbursement and offset staff time to help support continued patient care. While these codes provided a framework for providers that allowed them to generate revenue and offer much-need clinical services to patients, adopting these has come with some room for improvement. Though the codes introduced in 2019, the changes for fee scheduling have clarified and refined these billing mechanisms for RPM in 2020. These new changes help providers break down the barriers associated with RPM and remote patient monitoring so you can deliver and bill for the care that your patients deserve.
For more information on coding and billing changes for remote patient monitoring and RPM, please visit accuhealth.tech
RPM Billing Codes in 2021
With 2021 right around the corner, there will be further changes to codes and other clarifications for physicians and other qualified healthcare staff. In 2019, CMS ruled that services for the codes were to be furnished to only those with chronic conditions. In the 2021 proposal, CMS clarifies that providers can use RPM services to analyze and collect physiologic information from patients with acute and chronic conditions. This not only opens up more room to collect revenue but also widen services for patients, especially those living in remote areas.
There is also clarification that RPM services are limited to a physician’s established patients. While CMS waives this during a Public Health Emergency (PHE), CMS does require that RPM services resume for established patients after the PHE ends. This suggests that during a PHE, a practitioner can render RPM services without having a new patient E/M service conducted.
Currently, there is no guidance on physicians using remote patient monitoring services in conducting a new patient E/M via a remote patient monitoring connection. For enrollments in an RPM program, Medicare remote patient monitoring services allow the use of real-time audio and video technology to satisfy the face-to-face element of an E/M service. Also, Medicare-covered remote patient monitoring services lists new patient E/M service codes (CPT Codes 99201-99205).
Billing and Furnishing of RPM Services and Consent
While RPM services are considered E/M (Evaluation and Management) services, CMS does state the physician or nonphysician practitioners who can order and bill Medicare for these types of services. A healthcare professional or a physician can only furnish CPT Code 99091. CPT Codes 99457 and 99458 can also be used by clinical staff under a physician’s general supervision.
Accordingly, the CMS 2021 proposed rule may also allow auxiliary personnel, on top of clinical staff, to furnish these services that are under the CPT Codes 99453 and 99454. This will be done under the general supervision of the physician. One thing to note is that the CPT descriptors don’t specify that the clinical staff is the ones that must perform the RPM services. They also state these RPM services are not considered Diagnostic Testing. This means a physician can’t order them to bill to an Independent Diagnostic Testing Facility. Consent for these RPM services can be taken at the time of the services are done. So far, there is no proposal for a permanent waiver for any RPM co-payments.
This CMS proposed rule will advance the ability of RPM services to not only drive revenue but improve on the experience of the patient’s care. Now until the end of September 2020, the CMS is open to comment regarding these upcoming proposals via electronic submission.
For more information on RPM billing and coding changes in 2020 and 2021, please visit accuhealth.tech