On November 2, The Centers for Medicare and Medicaid Services (CMS) released the 2024 Final Physician Fee Schedule, which included several clarifications for Remote Patient Monitoring (RPM) and Remote Therapeutic Monitoring (RTM).
Here’s what the Final Rule had to say about RPM:
Finally, RPM is Reimbursable for FQHCs and RHCs
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. Read more details in our recent blog about the new reimbursement.
RPM is only for “Established Patients”
During the Public Health Emergency (PHE), RPM could be furnished to new patients, without having to undergo a new patient Evaluation and Management. Now that the PHE is over, RPM can only be furnished to established patients.
However, CMS also clarified that if a patient started RPM during the PHE without being an established patient, they are “grandfathered” in, and will be considered an established patient.
16 Days of Measurement is Required for 99454, but not 99457 or 99458
In the Proposed Rule, CMS stated that remote monitoring codes require at least 16 days of measurement in a 30-day period. In the Final Rule, CMS clarified that the 16-day requirement applied to the set-up and device codes (CPT 99453 and 99454) but not the treatment management codes (CPT 99457 and 99458).
RPM Can Only Be Billed Once Per Patient, Per 30 Day Period
In the Final Rule, CMS emphasized that even when multiple medical devices are provided to a patient, “the services associated with all the medical devices can be billed by only one practitioner, only once per patient, per 30-day period and only when at least 16 days of data have been collected.”
This is a key reason Rimidi does not require RPM patients to get a kit of multiple devices, and encourages providers to focus on the devices that are most medically necessary for the patient.
RPM or RTM (but not both) Can Be Billed Concurrently With Other Services
As long as the time and effort is not counted twice, RPM or RTM can be billed concurrently with: Chronic Care Management (CCM), Transitional Care Management (TCM), Behavioral Health Integration (BHI), Principal Care Management (PCM), and Chronic Pain Management (CPM).
CMS Clarified RPM and RTM Rules During the Global Surgery Period
RPM or RTM is separately reimbursable during the global period where the billing provider is not the provider that is receiving the payment for the global procedure. For example, if an orthopedic surgeon is getting a global payment for a knee surgery, but that patient’s glucose is also hard to control while they are inpatient, they would still qualify for a diabetes discharge program under a separate provider.
Rimidi can support your RPM, RTM, and CCM initiatives in one platform. Contact us today for more information.
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