Remote Patient Monitoring & the Proposed Medicare Physician Fee Schedule

How Accuhealth navigates RPM services through the proposed changes to the 2021 MPFS.

The Centers for Medicare and Medicaid Services proposed a new Medicare Physician Fee Schedule for 2021, which has several implications that may affect Remote Patient Monitoring Programs throughout the United States.

This announcement includes critical changes to factors surrounding the provision and reimbursement of telehealth services. It also clarifies various elements related to RPM codes already in use by both systems.

While many of these changes are creating anxiety throughout the remote patient monitoring industry, Accuhealth’s services are designed to meet these changes head-on. Our services have been created to specifically harmonize with these potential shifts in how RPM can be implemented, in ways that protect and maximize any clinic’s capacity to provide and scale these programs.

BILLING - Who Can Charge for RPM?

The 2021 Proposed Medicare Physician Fee Schedule more specifically defines which providers can bill for RPM services. The Centers for Medicare and Medicaid Services have now defined RPM as falling under Evaluation and Management services. Because of this, only physicians and practitioners who are qualified providers of E/M services are permitted to bill for Remote Patient Monitoring.

This affects several key players within the medical field, including physical, occupational, and other therapists, as well as clinical psychologists, who unfortunately do not fall under full eligibility criteria to provide E/M services. Currently, these RPM CPT Codes are not inclusive to the CMS’s rules surrounding eligible E/M services billable by these practitioners.

In addition, the CMS’s new proposed fee schedule rules that RPM services are not diagnostic tests, and are therefore not eligible billable services for Independent Diagnostic Testing Facilities.

However, the CMS’s new announcement states that RPM services are both available and billable for patients with acute and chronic medical conditions.

For Accuhealth clients, this is good news. Primary and speciality care doctors will not be impacted by this change, and may in fact see an uptick in demand from patients looking to transition their RPM service from their therapist to their doctors.

The Physician / Patient Relationship

Before COVID-19 caused unprecedented disruptions in healthcare provision, RPM was only permitted to be ordered by a healthcare provider with a previous, established relationship with a patient. However, the onset of the pandemic led to the CMS removing this requirement temporarily, in order to reduce barriers in accessing healthcare during mandatory isolation and social distancing.

Now, the newly proposed MPFS restores the “established relationship” rule. This means that doctors and practitioners providing RPM services must provide Evaluation and Management services to a patient before RPM care provision can begin.

As it stands, the CMS has not fully clarified whether these E/M services must be conducted in-person, or if RPM can be ordered as a component of initial E/M services. However, the MPFS states that an episode of care begins “when the remote physiologic monitoring service is initiated and ends with attainment of targeted treatment goals.”

This is yet another area where Accuhealth’s clients will not be impacted. Since its inception, Accuhealth’s structure has always been Physician First. We subscribe to the belief that patients adopt and adhere to RPM services when delivered as part of a holistic care plan by their established primary or specialty care doctor.

Patient Consent

The Proposed MPFS seeks to permanently allow patient consent for RPM services to be received at the moment of RPM services being “furnished”. It also elaborates that CPT code descriptors for 99453 and 99454 remain unspecified as to whether clinical staff must perform these services.

Instead, they propose that auxiliary personnel, or non-clinical staff, be allowed to perform these RPM services, and that consent may also be obtained by these personnel, as long as there is general supervision by licensed physicians and practitioners.

This is great news for clinics hoping to create their own RPM programs, as it means they can use contracted providers to implement RPM services. These individuals can furnish and set up devices for RPM services under the new proposed MPFS, and can supply devices under the supervision of a qualified physician or practitioner who is billing for these services.

Accuhealth’s turnkey RPM solution perfectly and effectively meets this new allowance. Accuhealth acts as an extension of your clinic, executing on every facet of the patient journey after referral. This allows providers at your clinic to operate at the top of their Medical License. Accuhealth’s full-circle RPM deployment and management means that we direct the complete backend and administration of your RPM program in its entirety. Accuhealth’s RPM solution is full-service, and is fully compliant with the new requirements imposed by the proposed 2021 MPFS.

Device Allowance

Another piece of good news from the Proposed MPFS relates to the types of devices that are required to be provided under CPT Code 99545. The CMS states that devices do not need to be FDA approved, but instead must still be “reliable and valid, and that the data must be electronically (i.e., automatically) collected and transmitted rather than self-reported.” It also states that a device must meet the FDA’s definition of a device for billing CPT Code 99454.

The Proposed MPFS goes on to state that only “connected” devices can be used for RPM services. This means that providers requiring patients to self-report device readings, or vendors who use only their own software to collect self-reported data, will not be supported under the 2021 MPFS.

Accuhealth exclusively uses FDA approved devices that are cellular connected, and that transmit data directly into our secure cloud and ultimately your EMR, where the data belongs. Our devices are also technologically accessible, and are easy to use by patients of all age groups. In this regard, not only is Accuhealth’s platform fully supported under the 2021 MPFS, it exceeds the requirements of quality and effectiveness as they relate to device functionality.

Interactive Communication

The Proposed MPFS requires “interactive communication” for CPT Codes 99457 and 99458. CPT Code 99457 is defined as being used for “remote physiologic monitoring treatment management services”, and states that it requires a live, interactive communication with either the patient themselves or their caregiver.

The Proposed MPFS further defines that “interactive communication for purposes of CPT codes 99457 and 99458 involves, at a minimum, real-time synchronous, two-way audio interaction that is capable of being enhanced with video or other kinds of data transmission”. It also states that “the interactive communication must total at least 20 minutes of interactive time with the patient over the course of a calendar month for CPT Code 99457 to be reported.”

Accuhealth’s proprietary calling feature directly meets this interactive communication requirement. This feature, coupled with no-cost telemedicine, allows clinics using our service to have unlimited audio and/or video interaction with their patients from within our Evelyn platform. 

Data Collection + Billing

The Proposed MPFS also defines how much data collection is needed in order to actually bill RPM services for CPT Codes 99453 and 99454.

Currently, the CPT Manual states that these codes should not be reported for any monitoring occurring less than 16 days. However, the CMS clarifies that during the Public Health Emergency measures currently in place, the requirement for data collection from a potential COVID patient must be 2 days minimum to bill for RPM.

However, when the Public Health Emergency measures end for the current pandemic, the previous 16 day data collection requirement will be reinstated. This means that 16 days of data within a 30 day period must be collected into order to successfully bill for RPM under CPT Codes 99453 and 99454.

Accuhealth is designed to support the ever-changing landscape of regulatory billing requirements for remote patient monitoring. Our industry-leading tool quickly adapts to meet current and future minimum adherence requirements for CPT Codes 99453 and 99454. Our tool also tracks the thirty (30) day billing cadence automatically, eliminating the need for manual tracking. This allows clinics to have peace of mind in knowing they are always in compliance with all CMS rules.

Accuhealth - The Provider that Makes the Cut

The landscape of remote patient monitoring is constantly shifting, with new requirements and regulatory oversight imposing new methods on administering remote medicine.

While these changes can be disruptive to many clinics implementing RPM programs, Accuhealth’s platform and services are specifically designed to navigate the current and anticipated shifts in MPFS compliance regulations.

Not only does Accuhealth future-proof its offerings, our data clearly shows that patients taking even one reading per week on our platform demonstrate a measurable improvement in their health.

Creating a remote patient monitoring program with Accuhealth guarantees compliance, scalability, and patient satisfaction. We anticipate and eliminate common issues faced by other RPM programs, and provide solutions that are easy to implement while creating long-term value.

Find out more about how you can improve your clinic’s offerings with Accuhealth at accuhealth.tech.