CMS Proposes RPM Reimbursement for FQHCs and RHCs: Top Takeaways from the 2024 Proposed Physician Fee Schedule

The Centers for Medicare and Medicaid Services (CMS) released its proposed 2024 Physician Fee Schedule (PFS) & Quality Payment Program (QPP). The rule contains several clarifications for virtual care and care meangement services, including remote physiologic and therapeutic monitoring.

RPM Clarifications for the End of the PHE

During the PHE, allowances and waivers for remote patient monitoring (RPM) were put in place. Now that the PHE has ended, CMS has clarified a few key points surrounding RPM.

• During the PHE, the CMS reduced the number of days of transmission for RPM from 16 to 2. Allowances for monitoring under 16 days per 30-day period and other PHE allowances have now expired.
• During the PHE, RPM could be furnished to both new and established patients, but as of the expiration of the PHE, RPM can only be furnished to established patients.

Additional Clarifications and Proposed Changes for RPM and RTM

In addition to these post-Public Health Emergency changes, CMS has also clarified rules and proposed some changes for RPM codes, and the newer Remote Therapeutic Monitoring (RTM) codes.

• CMS is finally proposing to provide Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) with the ability to receive payment for RPM/RTM outside of RHC all-inclusive rates and FQHC per visit payments. The PFS is proposing to include RPM/RTM in general care management services (G0511).
• RPM and RTM codes cannot be billed concurrently, though there is some confusion as to whether RPM and RTM services can be billed for the same patient when ordered by different physicians.
• RPM codes can only be billed once for each patient every 30 days regardless of the number of remote monitoring devices that a patient uses. For example, if the patient has both a glucometer and a blood pressure cuff, the RPM codes can still only be billed one time for that patient in a 30-day period.
• RPM and RTM codes can be billed with care management services CCM/TCM/BHI, PCM, and CPM.

Rimidi Supports both RPM and RTM

Rimidi’s Clinical Management Platform was built to support RPM and RTM, by combining patient-generated health data from connected devices with clinical data from the EHR to drive patient-specific clinical insights and actions through embedded clinical decision support cards. We know that proactive, continuous, virtual models of care like Remote Patient Monitoring are crucial for patients with chronic conditions. We are thrilled to see the 2024 Proposed Rule include RPM and RTM reimbursement for FQHCs and RHCs, and will continue to advocate for policies that make delivering this type of care possible.