Make Your Voice Heard on New RPM Codes for CMS
By now you’ve probably heard that the Centers for Medicaid & Medicare Services (CMS) has issued its proposed 2019 Medicare Physician Fee Schedule and Quality Payment Program. While it contains a number of changes that affect physician documentation of care, drug pricing, and transparency, there are also three items that should be of particular interest to organizations that want to take advantage of the benefits of remote patient monitoring (RPM).
Essentially, CMS is recommending augmenting the CPT 99091 code with three new reimbursement codes that make it easier and less onerous (clinically and financially) to bring RPM to the patients who need it. That’s great news for organizations that are already using it as well as those who are considering it.
We’ll look at the specifics in a minute, but I think it’s important up-front to mention that the public comment period ends August 31, 2018. CMS takes this process seriously, so if you like what you see after looking into the changes (and you should), be sure to add your support by leaving a comment.
The more positive comments CMS receives, the more likely these changes are to be incorporated into the final rule. On the other hand, if you don’t comment by August 31 and they are not part of the final rule, complaining after the fact will be of little value.
As to the changes themselves, there are three key proposed rule changes that affect RPM. The first, CPT 994X9, offers a 10-minute reduction in the treatment time required to qualify for reimbursement. Under CPT 99091, physicians must document spending at least 30 minutes per 30-day period on RPM-related activities such as collection and interpretation of physiologic data stored and transmitted digitally by patients or their caregivers. The new code reduces the time to 20 minutes, a 33 percent savings per patient. It also places a specific timeframe on data collection, making it easier to track.
More significantly, CPT 994X9 changes who at the provider can offer these services. Under CPT 99091, only “physicians or qualified health care professionals” were allowed to deliver those 30 minutes of RPM services. That meant those “physicians or qualified health care professionals” were often performing tasks well below their license level, such as gathering data and teaching Medicare patients how to use the equipment. That’s a lot of expensive time being spent to collect a reimbursement rate of $58.68 per member per month.
Under the new CPT code, clinical staff will be able to perform many of the services associated with implementing and maintaining an RPM program under general supervision (rather than direct physician supervision). This change will make offering RPM services far more practical, encouraging their expanded use.
Another significant change is CPT 990X0, which offers separate reimbursement for the work associated with onboarding a new patient, as well as setting up and training the patient on the equipment. Previously, that cost fell on the providers, which was definitely a stumbling block to acceptance and use. By paying for set-up and training, CMS removes that financial burden while at the same time promoting provider behaviors that will lead to better outcomes.
Finally, CPT 990X1 puts a code in place for supplying the device and monitoring data and alerts on a daily basis. This change will offer reimbursement for one of the most important tasks associated with RPM – keeping track of the condition of patients (especially those with chronic conditions) to stay ahead of adverse events.
One additional point to be aware of is that some of the proposed codes can only be used with current patients. If you are going to leave a comment, we suggest you ask CMS to remove this limitation so RPM can be offered to new patients who need it as well. Removing that restriction will enable patients to seek out providers who offer RPM if their current one does not.
Some of the codes have frequency limitations imposed on them. If you have experienced those limitations in the past you know how frustrating they can be. Be sure to ask CMS to remove those limitations so patients can get remote care at the level they need.
Finally, do express support for the CMS direction to move supervision from direct physician supervision to “general supervision,” freeing up the ability for virtual care call centers to facilitate patient monitoring on behalf of providers.
There is a lot of potential here to help expand the use of RPM. Again, be sure to go to the CMS website and leave your comments to ensure your voice, and the voice of the industry, is heard.
For a fact sheet on the CY 2019 Physician Fee Schedule proposed rule, please visit: https://www.cms.gov/Newsroom/MediaReleaseDatabase/Fact-sheets/2018-Fact-sheets-items/2018-07-12-2.html
To view the CY 2019 Physician Fee Schedule proposed rule, please visit: https://s3.amazonaws.com/public-inspection.federalregister.gov/2018-14985.pdf
For a fact sheet on the CY 2019 Quality Payment Program proposed rule, please visit: https://www.cms.gov/Medicare/Quality-Payment-Program/Resource-Library/2019-QPP-proposed-rule-fact-sheet.pdf
To view the CY 2019 Quality Payment Program proposed rule, please visit: https://s3.amazonaws.com/public-inspection.federalregister.gov/2018-14985.pdf
For a fact sheet on the Medicare Advantage Qualifying Payment Arrangement Incentive (MAQI) Demonstration, please visit: https://www.cms.gov/Newsroom/MediaReleaseDatabase/Fact-sheets/2018-Fact-sheets-items/2018-07-12.html