It is an exciting time in the world of digital health! The Centers for Medicare and Medicaid Services (CMS) has released its final 2020 rules, which directly impacts remote patient monitoring (RPM) services. This falls on the heels of 2019's reimbursement changes for providers using RPM under the following CPT Codes: CPT 99453, CPT99454, and CPT 99457.
Digital health companies have been anticipating these changes with an understanding of how they can improve the adoption of RPM as well as the health of their patients. The addition of these CPT codes allows for a greater flexibility for providers that opt to utilize RPM services for the patients they serve.
The two changes that were recently finalized include allowing RPM to be provided “incident to” under general supervision, and for CPT Code 99458 to be used as an add-on code for patients who received an additional 20 minutes of RPM services in a given month. Both new rules will go into effect on January 1, 2020.
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“Incident to” billing of CPT Code 99457
When the CPT codes for RPM were created earlier this year, the CMS stated that RPM services could only be delivered by a physician and not by an “auxiliary personnel incident to the practitioner’s professional services.” An “incident to” service is defined as a service rendered under the supervision of a physician and/or qualified health care professional and then billed to Medicare in the name of the physician and/or qualified healthcare professional.
In April of 2019, the CMS stated that it would allow for “incident to” billing by auxiliary personnel if they were under direct supervision, which meant they were in the same building at the very same time. This new rule allows for general supervision instead of the direct supervision that was required prior to April of 2019; thus, CPT codes 99457 and 99458 can be billed under general rather than direct supervision.
General supervision allows physicians to use telemedicine to conduct general supervision with their auxiliary staff. Furthermore, this rule states that the physician and/or other qualified healthcare professional who is supervising auxiliary staff does not have to treat the patient receiving RPM services, yet the supervising physician/qualified healthcare professional can bill Medicare for the “incident to services”.
This rule extends the flexibility of the RPM services and does not exclusively put the burden solely on the physician and/or qualified healthcare professional. This rule will change the landscape of the current business models being used for RPM services and will enhance them greatly.
New RPM Code for Extra 20 Minutes
The CMS also created a new rule that will allow for billing after the first 20 minutes of RPM services, which is currently billed under CPT 99457. Patients who received an additional 20 minutes of RPM services and require interactive communication with clinical staff/physician/qualified healthcare professional can be billed under CPT code 99458. It's estimated that reimbursement will be at the rate of approximately $43 per month.
In conclusion, these new rules and CPT codes demonstrate that the CMS recognizes the importance of RPM services and its power to minimize the gaps in our current healthcare system. All patients can benefit from these services and these changes will certainly increase providers’ chances to adopt a medical model that includes RPM services.
