First, it's important to understand what the PHE period is and how it affects RPM. The PHE was declared in response to the COVID-19 pandemic, and it allowed for a number of changes to the way healthcare is delivered in the United States. One of these changes was the expansion of Medicare coverage for RPM services, allowing physicians to provide remote monitoring for patients with chronic conditions and other health issues.
With the PHE period set to end on May 11, 2023, however, the rules around RPM are set to change. After this date, Medicare coverage for RPM services will be subject to the usual reimbursement rules, and physicians will need to ensure that they are providing these services in compliance with all applicable regulations. To maintain compliance, clinics and referring providers need to make note of the following:
- If you have not seen the patient in the last 12-months, it’s necessary to establish an initiating visit in order to refer the patient for RPM services;
- CPT Code 99454 is subject to the usual reimbursement rules requiring sixteen (16) successful days of synchronous physiological data transmission out of every thirty calendar days. You can expect on average that anywhere from 20% to 40% of your current patients fall short of this requirement. Remind your patients the importance of maintaining their daily habit of checking their vitals and taking their medications.
- Document all synchronous patient interactions with your clinic. That means any phone call and/or SMS to and from your patient should be documented in the patient's chart and/or within the software tool your clinic is utilizing.
While this may sound like bad news for physicians who have come to rely on RPM as a valuable tool for patient care, the impact of the PHE can be minimized by further championing this program with your patients and internally at your clinic.
To ensure that they are using RPM effectively and in compliance with all applicable regulations, physicians should work with a trusted RPM vendor that can help them navigate the changing healthcare landscape. This vendor should have a deep understanding of Medicare reimbursement rules and other regulatory requirements, as well as the technical expertise needed to provide effective RPM services.
Overall, while the end of the PHE period for RPM may be a cause for concern for some physicians, it is important to remember that RPM remains a valuable tool for patient care. By working with a trusted RPM vendor and staying up-to-date on all applicable regulations, physicians can continue to provide high-quality care for their patients using RPM technology.