2021 Medicare Remote Patient Monitoring Changes:

FAQs on CMS’s Final Rule

Medicare has been expanding coverage for Remote Patient Monitoring (RPM) over the last several years. On December 1st, 2020, they released the latest updates to their new reimbursement policies.

The 2021 Physician Fee Schedule final rule issued by the Centers for Medicare and Medicaid Services (CMS) provides clarifications on requirements for RPM and finalizes changes proposed in August 2020. It also offers expanded guidance on the recent update that qualifiesauxiliary personnel to perform services under general—rather than direct—supervision for “incident to” billing.

Here are seven of the most frequently asked questions we have received about RPMservices covered by Medicaresince the latest updates to the 2021 final rule from the CMS:

1. Who is qualified to order and bill Medicare for RPM services?

CPT codes for RPM reimbursement fall under the umbrella of E/M services. Because of this, physicians and practitioners must meet the eligibility requirements for billing E/M services to bill for RPM codes 99453, 99454, 99457, and 99458. Be sure to check your local and state laws as requirements can vary by location.

2. How does the CMS define remote patient monitoring?

Remote patient monitoring is a form of outpatient care that entails the recording and examination of physiologic data from a patient experiencing a chronic and/or acutehealth condition or illness. This data is then used to create and monitor the patient’s treatment plan. Medicare offers five main CPT codes for RPM reimbursement: 99091, 99453, 99454, 99457, and 99458.

3. Are only patients with chronic conditions qualified for RPM coverage?

No. While this was previously the case, the 2021 Medicare changes establish that RPM services and reimbursements can now be used to treat acute patients in addition to those who have chronic health conditions.

4. Are RPM services available to both established and new patients?

The 2021 Final Rule makes it clear that only “established patients” are eligible to receive RPM services. This requirement was temporarily waived due to the ongoing Public Health Emergency (PHE) caused by the COVID-19 pandemic. Upon the waiver’s expiration,billing for RPM reimbursements will require that patients have an established relationship with the ordering qualified healthcare professional.

5. What meets the CMS’s definition of “interactive communication” with patients?

CPT code 99457 covers the first 20 minutes of RPM care in a calendar month, and CPT code 99458 covers an additional 20 minutes. These codes require “interactive communication” with a patient; however, there was some confusion as to how the CMS defined such communication.

The Final Rule clarifies that this must entail a two-way, synchronous conversationbetween the patient, or their caregiver, and a member qualified on their care team, such as an appointed case manager or the physician. To be clear, the twenty minutes described in the CPT codes must have interactive communication in order for the claim to be billed.

6. Which RPM devices qualify for Medicare coverage?

Equipment and devices for RPM must fulfill what the FDA defines as a medical device, which is detailed in the Federal, Food, Drug and Cosmetic Act, section 201h.

Such devices must offer reliable readings of physiologic data and must be considered necessary for diagnosis and ongoing treatment as part of the patient’s care plan.

7. How often must the patient transmit vital data via the device in order for the equipment codes to be billable?

ForCPT codes 99453 and 99454, patient data must have utilized the equipment with a vital transmission recorded on at least 16 days per 30-day period.

How Telos Health Solutions Can Help

Telos RPM+ is our cloud-based software solution. It is easy to set-up, extremely cost efficient, and offers unique workflow optimization. This customization ensures that it will accomplish your company-specific 2021 RPM and Telehealth goals.

Our KPI dashboarding tools allows management teams to easily oversee the health of the program as well as quickly identify and respond to our patients specific needs. To ensure that we keep up with the latest advances in both medical billing and technology, Telos offers continual software and device training. We also provide best practice training, education guides, and sample templates for policies and procedures.

Customize your physician remote health monitoring with Telos Health Solutions today!

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