Not only did three new remote patient monitoring RPM CPT codes get added to permitted telehealth reimbursement policies in January of 2019, but now the Centers for Medicare and Medicaid Services (CMS), has issued a change to allow the reimbursable professional to get paid for services delivered by supervised auxiliary staff through RPM. But first, what is remote patient monitoring (RPM)? Typically used either in or at a distance from the clinician’s office, RPM involves the regular (daily) measuring and reporting of health functioning. Typically, RPM technology can involve peripheral attachments to one’s smartphone or independent devices such as built home-health stations to monitor and report conditions such as:
- glucose for patients with diabetes
- heart or blood pressure monitors for patients receiving cardiac care
- pulmonary function monitors for patients with asthma or emphysema
- some behavioral issues
In behavioral health, RPM may be housed in specialized technology known as integrated devices (such as NeuroFlow) or other apps and devices designed to measure algorithms such as heart rate variability.1
2019 RPM CPT Codes
In November of 2018, CMS announced reimbursement for RPM in its final 2019 Physician Fee Schedule and Quality Payment Program, which took effect on January 1, 2019. To simplify adherence to the 2,378-page rule, CMS also issued an abbreviated fact sheet summarizing the changes. The three new CPT codes for RPM are:
- CPT code 99453: Remote monitoring of physiologic parameter(s) (eg, weight, blood pressure, pulse oximetry, respiratory flow rate), initial; set-up and patient education for the use of equipment.
- CPT code 99454: Remote monitoring of physiologic parameter(s) (eg, weight, blood pressure, pulse oximetry, respiratory flow rate), initial; device(s) supply with daily recording(s) or programmed alert(s) transmission, each 30 days.
- CPT code 99457: Remote physiologic monitoring treatment management services, 20 minutes or more of clinical staff/physician/other qualified healthcare professional time in a calendar month requiring interactive communication with the patient/caregiver during the month.
Auxiliary Services that Are Incident To
Next, in a technical correction announced on March 14, CMS changed the billing code definition for RPM, giving auxiliary healthcare providers permission to use mHealth for care management and coordination (CCM) as incident to the or other reimbursable professional’s services. More specifically, CMS modified CPT code 99457 to allow auxiliary services delivered by staff to be billed for services that are furnished incident to in-office services or in a client’s/patient’s home when directly supervised by the physician or other reimbursable professional as defined by CMS. Given that many RPM programs are designed to allow care managers rather than physicians or other reimbursable professionals working in teams, it would only make sense that auxiliary staff could deliver billable services when supervised by any reimbursable professional. This is particularly true when such services are managed through other licensed professionals approved by CMS for telehealth service delivery, such as psychologists, nurse practitioners and others.
Billing CPT code 99457 for services that are incident to the services of the billing professional means that nurses, licensed care managers such as unlicensed social workers can use RPM apps and dedicated devices to identify which clients/patients need immediate care. This shift in billing codes then, allows the billing professional to assign tasks related to managing the output of software to other care team members, thereby freeing reimbursable professional to work at the top of his or her licensed abilities.
Type of RPM Supervision is the Key
However, the CMS legal revision imposes limitations with regard to the type of supervision needed for the care team’s services. As written, the change still requires “direct supervision” rather than “general supervision.” With direct supervision, the reimbursable professional must be in the same building as auxiliary professionals when the service is rendered. With general supervision, the billing professional could be in a separate location to supervise auxiliary staff members, such as when using a telehealth platform for that supervision. Nathaniel Lacktman, a partner and healthcare lawyer with Foley & Lardner clarified the CMS announcement further, identifying the issue of supervision as being central to reimbursement. In his blog, Mr. Lacktman wrote:
When the final rule for the 2019 Physician Fee Schedule was published in November 2018, CMS stated that CPT code 99457 describes professional time and ‘therefore cannot be furnished by auxiliary personnel incident to a practitioner’s professional services. With this technical correction, CMS deleted that sentence, replacing it with: ‘We thank commenters and confirm that these services may be furnished by auxiliary personnel incident to a practitioner’s professional service.’ This is a welcome revision long-awaited by telehealth providers.
Lacktman further explained:
Unfortunately, the recent technical correction for RPM does not state that CPT code 99457 can be delivered under general supervision. Indeed, CMS has not revised the RPM regulations to allow an exception to the default requirement of direct supervision. While the correction is good news for providers and patients, changing the RPM rules to expressly allow incident to billing of CPT code 99457 under general supervision will make a huge difference in operations and business models, thereby allowing more patients to enjoy the quality-improving benefits of remote patient monitoring.
1 Before purchasing, the licensed behavioral professional is encouraged to speak with the device manufacturer to obtain actual reimbursement information related to the specific device or service as well as CMS reimbursement policies that are dependent on the professional’s type of licensure. In the absence of such information, reimbursement may be a challenge. Please comment below with any helpful information.