CMS Revises 2021 Remote Patient Monitoring Rules, Issues Correction

Foley & Lardner LLP

Foley & Lardner LLPCMS just issued a correction to its guidance on 2021 Medicare rules for remote physiologic monitoring (RPM) services. The correction is effective January 1, 2021 and revises the preamble commentary in the Medicare Physician Fee Schedule Final Rule, previously published on December 1, 2020. It adds language that was inadvertently deleted from the Final Rule, summarizing and responding some public comments. Here is a summary of the new changes:

20 Minutes of Time Includes, but Not Limited to, “Interactive Communication” with Patient

The required 20 minutes of time associated with CPT codes 99457 and 99458 includes care management services, as well as synchronous, real-time interactions with the patient. CMS clarified the “interactive communication” element contributes to the total time, but is not the only activity that can be included when calculating the 20 minutes per month. Put another way, 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 the month. This clarification reverses the commentary in the Physician Fee Schedule Final Rule, but is consistent with the statements in CMS’ associated Fact Sheet published the same day.

RPM Billing by One Practitioner, Per Patient, Per Period

Only one practitioner can bill CPT codes 99453 and 99454 during a 30-day period and only when at least 16 days of data have been collected on at least one medical device. “Even when multiple medical devices are provided to a patient,” CMS explained, “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.” Of course, the services must also be reasonable and necessary in order to be reimbursed under the Medicare Program.

Know Your Remote Monitoring Codes

CMS reminded practitioners the universe of RPM-related codes is not limited to just CPT codes 99091, 99453, 9454, 94557, and 99458. There are additional, more specific codes available for billing that allow remote monitoring (for example, CPT code 95250 for continuous glucose monitoring and CPT codes 99473 and 99474 for self-measured blood pressure monitoring). When a more specific code is available to describe a service, the CPT Handbook dictates that the more specific code should be billed. Remote monitoring can often have two facets. The first part is collecting and monitoring the data, whereas the second part is treatment/ management services of the conditions monitored with the data. Practitioners should consult with their certified billing and coding professionals to help ensure accurate coding and claim submission.

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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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