Remote Monitoring: CMS Clarifies Guidance, Proposes Rural Provider Payment, Requests Information on Digital Therapeutics

McDermott Will & Emery
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Over the past several years, the Centers for Medicare and Medicaid Services (CMS) has expanded payment for care management and remote monitoring services in an effort to recognize and pay for non-face-to-face services that improve care coordination for Medicare beneficiaries. In connection with the calendar year 2024 Medicare Physician Fee Schedule (MPFS) proposed rule, CMS clarifies its existing guidance for remote monitoring services, including both remote physiological monitoring (RPM) and remote therapeutic monitoring (RTM) services, and proposed several additional clarifications. CMS requests additional information from healthcare providers and other stakeholders regarding the use of remote monitoring, remote cognitive behavioral therapy (CBT) and other digital therapeutic modalities.

CMS also proposes modifications to the way rural health centers (RHCs) and federally qualified health centers (FQHCs) are reimbursed for care management services, and proposed to establish reimbursement for remote monitoring services furnished by RHCs and FQHCs. Comments and responses to the requests for information included in the proposed rule are due to CMS by September 11, 2023.

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