On December 1st, the Centers for Medicare and Medicaid Services (CMS) published their 2021 Final Rule Physician Fee Schedule including billing for remote physiologic management (RPM), covered under CPT codes 99091, 99053, 99054 99457 and 99458. CMS also issued a Fact Sheet explaining more about the changes for the new calendar year.
The CMS Fact Sheet states:
We clarified that for CPT codes 99457 and 99458, an “interactive communication” is a conversation that occurs in real-time and includes synchronous, two-way interactions that can be enhanced with video or other kinds of data as described by HCPCS code G2012. We further clarified that the 20-minutes of time required to bill for the services of CPT codes 99457 and 99458 can include time for furnishing care management services as well as for the required interactive communication.
You may have noticed, as we did, that there was a discrepancy between the published Rule and the Fact Sheet. According to the published Rule, which is generally taken as the final legal document, the codes only cover interactive communications during the initial 20-minute period (CPT 99457) and any follow-up interactions (CPT 99458) lasting up to 20 minutes. The Fact Sheet, however, says the codes cover interactive communications plus remote care management services.
This discrepancy represents a huge potential swing in revenue that could also have a severe impact on health outcomes. So rather than guess, our Vivify team immediately went right to the source to obtain clarification.
On January 7, CMS confirmed to our team that the Fact Sheet is correct. Providers can bill CMS both for interactive communications and remote care services rendered under CPT 99457 or 99458, which is great news. Revenue cycle management leaders within healthcare organizations should be made aware of the clarified information and bill CMS accordingly.
CMS also informed us that they are going to issue a correction notice to update and correct the final Rule to align with what is stated on the Fact Sheet. Once that correction notice has been issued we will update this blog post and link it to a white paper on CPT codes for 2021 that you can download.
Other changes for 2021 will be addressed in our white paper.