CMS Clarifies RPM Reimbursement

Rivkin Radler LLP

Rivkin Radler LLP

The Centers for Medicare & Medicaid Services (CMS) recently released corrections to its 2021 Physician Fee Schedule final rule that was published on December 28. Some of the corrections clarify reimbursement requirements for remote patient monitoring (RPM), which entails gathering and interpreting physiologic data from patients at home.

The December 28 final rule had stated that in order to qualify for RPM reimbursement for a patient, a healthcare provider would need to have at least 20 minutes of interactive communication with the patient in a calendar month, in addition to 20 minutes of data review and interpretation. CMS has now clarified that there is only one 20-minute requirement that can include both reviewing RPM data and communicating with the patient about the data.

“We agree with commenters that our description of the required 20 minutes of time associated with CPT codes 99457 and 99458 should include care management services, as well as synchronous, real-time interactions,” CMS stated. “We are clarifying . . . that the 20-minutes of intra-service work associated with CPT codes 99457 and 99458 includes a practitioner’s time engaged in ‘interactive communication’ as well as time engaged in non-face-to-face care management services during a calendar month.”

CMS also clarified that other CPT codes for RPM, 99453 and 99454, “should be reported only once during a 30-day period; that even when multiple medical devices are provided to a patient, the services associated with all the medical devices can be billed by only one practitioner, only once per patient, per 30-day period, and only when at least 16 days of data have been collected; and that the services must be reasonable and necessary.” CMS pointed out that more specific CPT codes, such as those for continuous glucose monitoring and self-measured blood pressure monitoring, should be used when applicable in lieu of the general RPM codes.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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