One of the latest announcements from The Centers for Medicare & Medicaid Services (CMS) confirms that the largest payer in the U.S. sees remote patient monitoring (RPM) as part of the future of care delivery. Why? Because next year, they will begin incentivizing use of connected technology to capture patient-generated health data.
Beginning January 1, 2018, clinicians can use the newly unbundled reimbursement code CPT 99091 to bill for the time they spend reviewing and interpreting data collected or transferred by a remote monitoring tool. The changes to this code will have significant implications for accelerating the adoption of remote monitoring tools into clinical practice.
How can clinicians position themselves to take full advantage of this new incentive, understand the changed guidelines, and determine how RPM could be incorporated into their practices? Read on.
How many RPM reimbursement dollars are you leaving on the table?
Reimbursement for Remote Patient Monitoring
As part of the Physician Fee Schedule Final Rule, CMS will activate CPT code 99091 (collection and interpretation of physiologic data) and unbundle it from chronic care management programs. This will allow clinicians to be reimbursed for time spent collecting and analyzing health data that is generated by a patient, digitally stored, and transmitted to the healthcare organization. They can be reimbursed approximately $60 per month per patient for a cumulative 30 minutes of collecting/interpreting data.
To bill for RPM services, clinicians will need to meet the following requirements and guidelines:
Clinicians must obtain advanced beneficiary consent for the service and document this in the patient’s medical record.
Clinicians must spend a minimum of 30 minutes accessing, reviewing, and/or interpreting data for a given patient per month. Time spent making modifications to the care plan as a result of reviewing the data, including communicating changes to the patient and/or their caregiver, and any associated documentation, can also be included.
For new patients, or patients not seen by the billing practitioner within one year prior to billing CPT code 99091, initiation of RPM services must occur during a face-to face visit with the billing practitioner, such as an Annual Wellness Visit or Initial Preventive Physical Exam.
CPT code 99091 cannot be reported more than once in a 30-day period for a particular patient.
A Significant Step Forward
Activating CPT code 99091 and assigning it for separate payment is a leap forward for remote patient monitoring. As CMS notes, “RPM services can be a significant part of ongoing medical care and we should recognize these services for separate payment as soon as practicable. CMS looks forward to forthcoming coding changes through the CPT process that we anticipate will better describe the role of remote patient monitoring in contemporary practice and potentially mitigate the need for the additional billing requirements associated with these  services.”
This is an astonishing and welcomed announcement since, for decades, CMS had turned a deaf ear to most forms of telehealth and any discussion of remote monitoring. So, will this change be enough to encourage more clinicians to adopt remote patient monitoring technologies to deliver care? Many proponents of the policy change believe that it will.
As Executive Director of the Alliance for Connected Care, Krista Drobac, notes, “The reason this is going to facilitate more use of remote patient monitoring is most medical providers want their patients to get better, and they realize that most care happens outside the medical facility. Viewing data digitally transmitted from a patient’s home gives the provider a clearer picture of what’s happening, and providers want that for purposes of good care.”
Along similar lines, Executive Director for the Connected Health Initiative, Morgan Reed, said in a statement, “Until now, connected health technologies have been effectively locked out of the most important part of America’s healthcare system, Medicare and Medicaid. These new rules will be an important step forward for America's connected health innovators, doctors, and most importantly, patients.”
Don’t leave reimbursement dollars on the table.
Although this policy change removes a major barrier previously facing clinicians to use RPM services, other challenges still remain. Take, for example, Medicare’s announcement several years ago for covering advance care planning (CPT 994979, 99498) and chronic care management (CPT 99490) services. Although many advocates believe this was a critical and necessary move, recent analysis has determined that very few practices are actually billing for either reimbursement.
This signals an opportunity for healthcare technology companies to step in to not only educate organizations and clinicians on the incentive opportunities available to them, but also to help them understand how technologies like RPM can be customized to fit their unique needs and workflows (e.g. billing), and aligned to their care delivery and strategic goals. This requires companies to come to the table with thoughtful approaches and conversations that are driven by clinicians’ goals, resourcing and workflows.
Is 2018 the year of RPM?
The future is bright for remote patient monitoring. In their final rule, CMS indicated that more work is forthcoming in 2018, aimed at exploring a broader recognition of RPM services, including compensating clinicians for technology costs, time spent enrolling patients, and value from solutions that are automating care management.
With CMS’ recognition of these services as a vital part of patient care, we are hopeful that this will pave the way for increased momentum to drive adoption. As RPM continues to change the way healthcare is delivered, improving patient outcomes, increasing access to care, and reducing costs, the time for clinicians to embrace these technologies is now.
Are you billing CMS reimbursements to their fullest? How can RPM technologies help your clinical teams add new dimensions to care?
Let's talk about it.