The 2024 Final PFS: FQHCs and RHCs can Bill for Remote Patient Monitoring

Since the Centers for Medicare and Medicaid Services (CMS) proposed that Federally Qualified Health Centers (FQHCs) and Rural Health Centers (RHCs) could bill for Remote Patient Monitoring (RPM) and Remote Therapeutic Monitoring (RTM) in the Proposed 2024 Physician Fee Schedule in July, stakeholders have awaited clarification in the final rule.

In the final rule released on November 2, CMS confirmed that beginning in 2024, FQHCs and RHCs will have the ability to receive payment for RPM and RTM outside of the RHC all-inclusive rates and the FQHC per visit payments.

Here are the details:

FQHCs and RHCs Can Bill for RPM and RTM Starting in 2024

• Under the general management code HCPCS G0511, FQHCs and RHCs will be able to receive payment for Remote Patient Monitoring and Remote Therapeutic Monitoring services, expanding the code, which already included other inherently non-face-to-face services like Chronic Care Management and behavioral health integration services.

• The expansion was meant to reflect the additional resources required for the unique components of RPM and RTM.

Adjusted G0511 Payment Amount can be Billed Multiple Times Per Month

• CMS used a revised methodology to calculate the reimbursement amount for G0511 by “analyzing the actual utilization of the services using a weighted average of the services that comprise G0511.” This resulted in a reduction of the reimbursement amount for this code from $77.94 in 2023 to $72.98 in 2024.

• Despite the reduced rate, there is good news: CMS clarified that G0511 can be billed multiple times for the same patient per month for all subcategory codes.

A key concern from stakeholders after the proposed rule was using the G0511 code for distinct services like Chronic Care Management and Remote Patient Monitoring would not sufficiently account for the resources required to provide these separate services.

CMS responded to the comments by clarifying that G0511 could be billed for the same patient more than once per month, as long as all the requirements are met. For example, a patient may be part of a Chronic Care Management and Remote Patient Monitoring program. If the requirements are met for each service, FQHCs and RHCs can bill Medicare for each in a given month.

Expanded Coverage Expected to Continue for RPM and RTM

The 2024 final rule is great news for FQHC and RHC Medicare beneficiaries, and it is anticipated that many Medicaid plans will follow suit. Providers can check their state Medicaid policies on the Center for Connected Health Policy website.

In addition, many proposed rule commenters suggested various ways to clarify billing for these separate subcategories under G0511, such as: “creating a more comprehensive set of HCPCS codes separated by service type or by time; or allowing RHCs and FQHCs to bill the full suite of care management codes the same way traditional fee-for-service providers or hospital outpatient departments bill for care management services.”

To this, CMS emphasized that it will consider these operational suggestions in future rulemaking, and will continue to track utilization rates for these codes and adjust the reimbursement rate as necessary.

What does this mean for your FQHC or RHC?

Our team is happy to answer any questions you have about G0511 and how Rimidi can support your Chronic Care Management, Remote Patient Monitoring, and Remote Therapeutic Monitoring Initiatives.