In the 2024 final rule for the physician fee schedule, the Centers for Medicare & Medicaid Services (CMS) introduced pivotal policies affecting remote physiologic monitoring (RPM) and remote therapeutic monitoring (RTM) services reimbursed under Medicare. This article provides an insightful breakdown of the key takeaways from the Medicare final rule 2024, offering valuable guidance to organizations adapting to these regulatory changes.
Medicare Final Rule 2024: RPM Exclusive to Established Patients The Medicare final rule 2024 underscores the exclusivity of RPM services to "established patients." This distinction reinstates the requirement for patients who initiated RPM during the Public Health Emergency (PHE) to transition into the category of "established patients." Those commencing RPM services after May 11, 2023, must undergo an initial evaluation to qualify. This emphasis aims to maintain structured RPM services, ensuring a solid foundation of familiarity with the patient's health history and treatment plan.
RTM's Unique Position In contrast, RTM services offer flexibility and do not mandate an "established patient" requirement. While an initial interaction evaluation is recommended, the Medicare final rule 2024 clarifies that an established patient relationship is not expressly necessary for RTM services, with potential future rulemaking to address nuances. This flexibility in RTM requirements enables practitioners to tailor their approach to individual patient needs, potentially streamlining the onboarding process for remote therapeutic monitoring.
Medicare Final Rule 2024 Billing for RPM and RTM The Medicare final rule 2024 clarified that specific remote monitoring codes require at least 16 days of data collection within 30 days. Treatment management codes (99457, 99458, 98980, and 98981) do not adhere to this 16-day requirement, offering practitioners increased flexibility. This clarification on data collection requirements ensures clear expectations for different remote monitoring codes and addresses concerns raised during rulemaking about the potential burden of a uniform 16-day requirement.
In a given 30-day period, only one practitioner can bill RPM/RTM services for a patient, even with multiple medical devices. This clarity streamlines billing processes while aligning with CMS's emphasis on reasonable and necessary services. Singular practitioner billing aims to prevent confusion and overlapping claims, ensuring that one healthcare professional coordinates each patient's remote monitoring services.
Billing RTM for Assistants Under General Supervision Physical therapists (PTs) and occupational therapists (OTs) can now bill Medicare for RTM services according to the Medicare final rule 2024. This includes services provided by their assistants (PTAs and OTAs), with the requirement of general supervision. This change fosters broader access to RTM services within private practice settings, recognizing the collaborative nature of healthcare and the contributions of various team members.
Concurrent Billing with Care Management Services According to the Medicare final rule 2024, practitioners can bill Medicare for RPM or RTM concurrently with certain care management services, preventing double counting of time and effort. This strategic approach allows practitioners to tailor patient care management services without compromising compliance. Concurrent billing reflects CMS's commitment to providing comprehensive and coordinated healthcare, encouraging practitioners to leverage a combination of services to meet diverse patient needs.
Global Surgery Period in the Medicare Final Rule 2024 Billing practitioners cannot bill Medicare for RPM or RTM services during global surgery periods. However, practitioners not receiving global service payments, such as therapists, can provide these services during the global period, ensuring flexibility in patient care. This distinction in billing practices aims to balance financial considerations while focusing on patient care continuity.
Separate Reimbursement: FQHCs and RHCs Starting January 1, 2024, Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) can separately bill Medicare for RPM and RTM services, departing from the previous all-inclusive rate model. This change aims to enhance reimbursement and align with coding requirements, recognizing the unique challenges and services provided by these healthcare entities.
RPM Exclusion from MSSP Primary Care Services While RPM CPT codes were considered for inclusion in the Medicare final rule 2024, they were ultimately excluded from the definition of primary care services for the Medicare Shared Savings Program (MSSP). This decision reflects CMS's commitment to maintaining the integrity of primary care services within the MSSP framework, aiming to prevent potential conflicts when specialists also bill RPM codes.
Understanding the Medicare Final Rule 2024 The Medicare final rule 2024 represents a significant milestone in the evolution of RPM and RTM Medicare billing. While it provides increased clarity, operational uncertainties persist, underscoring the importance of stakeholder engagement in future rulemaking to optimize the utilization of these services in advancing digital health models for patients. Staying informed and actively participating in rulemaking processes will be essential for healthcare providers navigating the evolving landscape of remote patient monitoring and therapeutic services while ensuring compliance with CMS guidelines.
Disclaimer: This article is provided for informational purposes only and should not be construed as legal, billing, or professional advice. The billing and coding requirements for RPM services may undergo rapid changes. It is advisable to seek guidance from a qualified medical billing professional before submitting claims for services to ensure compliance with all current requirements.