In early November, the Centers for Medicare & Medicaid Services released its 2023 Physician Fee Schedule (PFS). final rule. I recently presented a online seminar on the topic, focusing on developments regarding care management and remote/virtual delivery of these services. There have been some significant changes, so I thought it would be helpful to provide a summary of some of the key things to know about the impact of the 2023 final rule on remote monitoring and related topics – along with the caveat that we await additional information on some topics and expect more clarity on others in future rules.
Remote therapeutic monitoring is the star
Of all care management services, remote therapeutic monitoring (RTM) received the most attention in the final rule. Before summarizing the RTM changes included in the rule, I thought it would be helpful to provide an overview of these services, which are only a few years old and have changed quite a bit since they were revealed.
The American Medical Association defines RTM services are those that “represent the review and monitoring of data related to the signs, symptoms, and functions of a therapeutic response.” This data may represent objective data generated by the device or subjective patient-reported inputs captured through “software as a medical device” (SaMD). RTM is billable by physicians, non-physician practitioners, and other qualified providers (e.g., physical therapists, dietitians, clinical psychologists).
Therapeutic remote monitoring and remote patient monitoring (RPM) are sometimes confused. RPM involves the collection of physiological/vital data from a connected medical device, while RTM involves the collection of non-physiological (i.e. “therapeutic”) data from a connected medical device . RPM is device-neutral, while RTM is currently limited to respiratory monitoring, musculoskeletal monitoring, and cognitive-behavioral monitoring, the latter of which is new for 2023 and discussed in more detail below .
The 2023 PFS proposed rule would have replaced existing RTM CPT codes 98980 (monitoring/treatment management services, first 20 minutes) and 98981 (monitoring/treatment management services, additional 20 minutes each) with four new HCPCS G codes – two that would be used by physicians and/or non-physician practitioners and two that would be used by qualified non-physician health professionals. This caused confusion, which is why CMS chose not to finalize the codes. For 2023, all eligible providers can continue to bill 98980 and 98981.
The full list of RTM CPT codes for 2023 is as follows:
- 98975: Initial Setup and Patient Education
- 98976: Supply of respiratory system monitoring device
- 98977: Supply of musculoskeletal system monitoring device
- 989X6: Supply of cognitive-behavioral therapy monitoring device (new for 2023)
- 98980: Treatment monitoring/management services, first 20 minutes
- 98981: Treatment monitoring/management services, each additional 20 minutes
I want to go back to why CMS proposed replacing the RTM CPT codes in the first place. The agency wanted to circumvent the established ban on general oversight for service codes other than evaluation and management (E/M). Although CMS decided to continue using the original CPT codes, the agency stated in its final rule that “any RTM service may be provided under our general oversight requirements.”
This is a big win for RTM services, as the relaxation of supervision requirements is expected to encourage increased service delivery. However, some questions remain as to who this statement applies to, as there are incidental billing restrictions for certain types of providers that can charge RTM. We hope to receive clarification on this point soon.
Important note regarding the new Cognitive Behavioral Therapy Monitoring RTM Device Procurement Code, CPT 989X6: At this time, there is no national reimbursement amount assigned to this code. This is a difference from other care management type remote monitoring codes. CMS said each Medicare Administrative Contractor (MAC) will develop its own pricing for CPT 989X6 until the agency “learns more about the devices used to provide the service.”
Despite pressure from vendors, CMS rejected the creation of a device-neutral RTM code, stating: “…it remains unclear whether generic device codes would undermine or block progress toward a more wide range of specific codes which would bring less ambiguity.” I expect a continued push to create such code that would align RTM billing devices with RPM billing devices, but CMS doesn’t seem very keen on the idea yet.
Remote Home Health Patient Monitoring
A notable development regarding remote patient monitoring appeared in the 2023 Home Health Prospective Payment System Rate Update Final Rule. Although CMS does not currently reimburse RPM for home health organizations, It was announced that CMS will begin requiring home health organizations to track the use of telehealth and remote monitoring through non-refundable codes that will document the types of telecommunications technologies used in health care benefits. home health.
Initially, home health agencies are asked to voluntarily begin reporting on January 1, 2023, with the requirement taking effect in July 2023. Codes that agencies must use include:
- G0320: Home health services provided by synchronous telemedicine delivered via a real-time two-way audio and video telecommunications system
- G0321: Home health services provided by means of synchronous telemedicine delivered by telephone or other interactive real-time audio-only telecommunications system
- G0322: Collection of physiological data stored digitally and/or transmitted by the patient to the home health agency (e.g., remote patient monitoring)
Note: Learn more about these new home health G codes in this MLN Matters article.
In 2021, CMS made permanent the rule requiring that documentation demonstrating the provision of remote patient monitoring or other services provided via a telecommunications system be included in a patient’s plan of care. However, CMS noted that a telecommunications service cannot be a substitute for a home visit ordered by the care plan or for eligibility or payment.
These developments demonstrate the multi-year trend in which CMS is collecting information and studying the viability and value of remote monitoring in home health settings and, more generally, outside of physician offices. Home health advocates have long advocated for CMS to begin reimbursing home health RPMs. The 2023 changes appear to be another step toward such coverage.
Preventive service updates
The 2023 PSF final rule included a few other important changes regarding preventive services. Two prevention services have had their HCPCS code descriptors changed. HCPCS G0442 was changed to “Annual Alcohol Abuse Screening, 5 to 15 minutes” and HCPCS G0444 was changed to “Annual Depression Screening, 5 to 15 minutes.” Codes currently require a minimum of 15 minutes of services. CMS also expanded Medicare coverage for certain colorectal cancer screening tests by reducing the minimum payment age to 45.
Note on chronic pain management
During my webinar, I spent time discussing the new service finalized in the 2023 PFS final rule, chronic pain management (CPM). Although CMS talks about CPM as if it were a “care management” service, the agency has designated chronic pain management as a “telehealth” service. Such a designation means that remote/virtual delivery of CPM must follow CMS telemedicine requirements rather than the more relaxed requirements of a managed care service. These requirements can stifle access and delivery of CPM services. These requirements also mean that CPM cannot, as currently described, be integrated into a remote care management program.
While the release of the CPM is encouraging, the substantial restrictions currently placed on the service should be considered in future regulation for chronic pain management to be another valuable remote service. Given the paths taken by other remote monitoring services, we hope that CMS will adjust this designation in future rulemaking to help increase access to CPM and further increase access to other remote monitoring services. distance for its beneficiaries.
Global Overview of Remote Monitoring and Preventive Care
The 2023 PFS final rule brings good news for remote monitoring and preventative care services and builds on positive developments seen in previous years’ final rules. It is clear that these services have solidified their place in our health care system, and CMS is committed to expanding their coverage. Remote therapeutic monitoring is now a viable and attractive service that practices are considering adding to an existing care management program, home health care appears to be on the right track toward reimbursement for remote monitoring services, and preventive care continues to undergo revisions that make its delivery easier. and bill for these services.
Daniel Tashnek, J.D.is the co-founder and CEO of Prevent health, a healthcare software company that simplifies the delivery of preventive clinical services, chronic care management and remote patient management. Prevounce also provides a connected health ecosystem and connected devices to health systems, insurers and employer wellness programs under its “Pylo” brand. Prior to founding Prevounce, Daniel was a healthcare attorney specializing in regulatory compliance, reimbursement, scope of practice and patient care issues.
This article was originally published on Medical Economics®.
