While many “RPM" initiatives continue to be small, they certainly punch above their weight. Simply put, RPM continues to offer immense benefits for patients and healthcare providers alike. Learn what crucial mistakes not to make when selecting a vendor to move your clinic to virtual care.
Among other things, patients can get more access to healthcare, leverage improved quality of care, and have much more support and peace of mind. On the other side, healthcare providers get a much closer look at their patients’ health data, which can lead to reduced readmissions, better patient outcomes, and recurring revenue.
RPM can be a win-win for both patients and healthcare providers. But having said this, healthcare providers aiming to launch and run an RPM program need to tread lightly. There are many different kinds of pitfalls and mistakes that can occur. Because of this, let’s take a deep dive into ten mistakes that you and your colleagues should avoid in your RPM program.
10. Failing to Have a Face-To-Face Visit
Face-to-face visits are a critical first step for delivering RPM care. As the billing practitioner, you need to have at least one face-to-face meeting with new patients or patients that you haven’t seen within one year before billing CPT code 99457. CPT code 99457 is a relatively new CPT code that deals with remote physiologic monitoring treatment management services. Ultimately, this face-to-face visit should be billed separately and can occur during things like annual wellness visits, level 2 through 5 office visits, or initial preventive physical exams.
9. Not Documenting Patient Consent
Simply put, you will need to get some documentation showing that your patients have consented to RPM. The Centers for Medicare and Medicaid Services (“CMS”) doesn’t explicitly say how you should obtain documented consent. Nonetheless, it is critical to have documentation that shows patients are actively opting in for RPM treatment. It’s also a good idea to have documentation in the patient’s medical record that shows why RPM is justified.
8. Failing to Use the Correct CPT Codes
Like providing other types of healthcare services, it’s critical to use the correct CPT codes when providing RPM care. While the first CPT code in the RPM world was introduced in 2018 (CPT code 99091), there have been several additional CPT codes added in the final 2019 and 2020 Medicare Physician Fee Schedules, so please make sure you’re using the updated codes from 2019 and onward.
CPT 99453, CPT 99454, CPT 99457, and CPT 99458 are the better codes to use when providing Remote Patient Monitoring services to your Medicare beneficiaries.
7. Not Using Medical Devices as Defined by the FDA
The 2019 Medicare Physician Fee Schedule requires that billing practitioners use FDA-defined “medical devices” to bill for RPM services.
Ultimately, you’ll want to make sure that devices within your RPM program comply with this definition. Notably, however, your device does not necessarily need to be “FDA-approved.” While it certainly won’t hurt, the guidance doesn’t seem to suggest that this is a strict requirement.
6. Failing to Have RPM Services Ordered by Physicians or Other Qualified Healthcare Professionals
When delivering RPM care to a patient, it is important to have those services initially ordered by physicians or other qualified healthcare professionals. The good news for healthcare providers is that physicians and other qualified healthcare professionals don’t necessarily need to deliver services after the initial order. For instance, clinical staff can provide services under CPT codes 99457 and 99458. The actual act of ordering RPM services, however, cannot be completed by clinical staff.
5. Failing to Reinforce Daily Reading Protocol
During the Initiating Visit with your patient, make sure to reinforce the “daily reading protocol”. Just one routine reading a day makes all the difference and will lead to greater patient adherence to the program and ultimately more and better data for the clinic to manage the patient’s healthcare plan. (Note - avoid the pitfall of recommending a cadence that is only 1 or 2 readings per week, as this can result in non-adherence altogether)
4. Failing to Track Interactive Time (or worse, doing it Manually)
This is a notable mistake when you are trying to get reimbursed by Medicare. Specifically, CPT codes 99457 and 99458 can only be billed if clinical staff members, physicians, or other qualified health care providers spend at least 20 minutes interpreting a patient’s physiologic data and using that data to manage or adjust the patient’s care plan. CPT code 99458 requires at least 40 minutes with these tasks. Consequently, make sure that you are monitoring this time. As a best practice, use a third party platform that tracks this interactive effort automatically, and that can serve as evidence in case of a Medicare inquiry.
3. Double Billing Interactive Time with Analogous Medical Services
When billing under CPT 99457 and 99458, you may also bill in conjunction with certain CCM, TCM, and behavioral health integration services codes. That being said, you must ensure that you aren’t counting the same interactive time for more than one billing code. For example, if you spend 20 min providing Remote Patient Monitoring services, those 20 min of time cannot also be allocated to Chronic Care Management Codes. Along with this, you cannot count any time on a day when you report an evaluation and management service for the same patient. Make sure that you are paying close attention to this when delivering RPM services.
2. Failing to Capitalize on the Rules Around “Incident-To” Billing
Under CPT codes 99457 and 99458, clinical staff members can provide RPM services as long as they are supervised under the general supervision of the billing practitioner. CPT codes 99457 and 99458 allow for “general supervision,” meaning that the billing practitioner does not need to be in the same office building as the staff member delivering care. This means that you can embrace an auxiliary model when delivering RPM services.
1. Not Getting Patient Feedback
Ultimately, RPM services are about delivering better patient outcomes. While you’ll certainly want to follow the data that you receive, you and your colleagues have great opportunities to improve your RPM program by speaking with patients. See what they like and see what they want improved. Doing this work will improve the RPM experience for both you and your patients.
Tread carefully, as you can see, many of these mistakes are completely avoidable. You and your colleagues have the power to avoid them—so long as you are paying attention. This diligence, however, will absolutely pay off. By avoiding these unforced errors, you and your colleagues will be able to utilize the benefits of RPM services. To learn about RPM and what mistakes not to make, visit accuhealth.tech.