CMS releases 2022 Physician Fee Schedule Proposal promising the expansion of RPM Coverage

On July 13, 2021, the Centers for Medicare and Medicaid Services (CMS) released the proposed 2022 Physician Fee Schedule (PFS). The PFS helps determine payment and reimbursement rates, clarifies evaluation and management policies, proposes policies for the 2022 performance year of the quality payment program, and includes other code provisions.

What does the 2022 PFS Say About Remote Patient Monitoring?

The 2022 PFS discusses the expansion of remote patient monitoring (RPM) into remote therapeutic monitoring (RTM). There are no revisions to the current RPM codes in the 2022 proposal. However, this new category of codes drawn out in the PFS is aimed at the goal of further expanding virtual care.

According to CMS, RTM is not a care management service like RPM is. RTM codes are generalized as medicine codes as opposed to Evaluations and Management (E/M) codes. The codes can refine E/M policies related to E/M visits, critical care services, and services furnished by teaching physicians involving residents.

The RTM codes are being created to help advance virtual care, give healthcare providers more opportunities for reimbursement in RPM programs, and expand the use of digital health tools to provide more comprehensive datasets to clinicians.

The new RTM codes are focused on respiratory system status, musculoskeletal system status, therapy adherence, and therapy response.

According to CMS, the codes are defined similarly to the original RPM Codes, and include:

• CPT code 989X1: Remote therapeutic monitoring (e.g., respiratory system status, musculoskeletal system status, therapy adherence, therapy response), initial set-up and patient education on use of equipment;
• CPT code 989X2: Remote therapeutic monitoring (e.g., respiratory system status, musculoskeletal system status, therapy adherence, therapy response), device(s) supply with scheduled (e.g., daily) recording(s) and/or programmed alert(s) transmission to monitor respiratory system, each 30 days;
• CPT code 989X3: Remote therapeutic monitoring (e.g., respiratory system status, musculoskeletal system status, therapy adherence, therapy response), device(s) supply with scheduled (e.g., daily) recording(s) and/or programmed alert(s) transmission to monitor musculoskeletal system, each 30 days;
• CPT code 989X4: Remote therapeutic monitoring treatment management services, physician/ other qualified health care professional time in a calendar month requiring at least one interactive communication with the patient/caregiver during the calendar month; first 20 minutes; and
• CPT code 989X5: Remote therapeutic monitoring treatment management services, physician/other qualified healthcare professional time in a calendar month requiring at least one interactive communication with the patient/caregiver during the calendar month, each additional 20 minutes (List separately in addition to code for primary procedure).

While questions still remain, overall, the new RTM codes provide new opportunities for health practitioners who could not previously bill RPM codes to provide service and bill for similar services to RPM.

CMS is accepting comments electronically on the proposed PFS through September 13, 2021 at 5 p.m. ET. Follow the “Submit a comment” instructions.

Rimidi recognizes the importance of a proactive approach to healthcare. Rimidi’s most recent Clinical Management Platform Enhancements, support a forward looking approach to healthcare. Through the expansion of RPM coverage and provisions to medicine E/M codes, intervention levels can increase and drive efficiency in clinical workflows.

To learn how Rimidi can support your Remote Patient Monitoring and other virtual care initiatives, visit Rimidi.com/solutions.