January 15, 2020 •Jeff LeBrun
Why It Just Became A Lot Easier To Deploy High-Performing Remote Care Programs (and Get Reimbursed for It)
Prior to the new, CMS-approved CPT codes being activated, remote patient monitoring was already a great option for practicing physicians. Patients loved the programs and the average primary care physician had the opportunity to generate more than $300,000 in revenue per year.
With the release of the 2019 CPT codes, changes were made to facilitate RPM setup and monitoring services for physicians and further incentivize its adoption. The biggest changes centered around allowing RN’s and assistants to handle the bulk of the RPM tasks. Not only that, but the 2019 CPT codes also made the reimbursement amounts higher and the collection process simpler.
However, there were still a few unclear guidelines in the 2019 CPT. Not everything was crystal clear or set in stone. For example, there were issues around what constituted “digital medical services”. Uncertainty around what kind of remote monitoring software and hardware was allowed within the 2019 CPT codes. This caused some problems for medical clinics that were using outdated RPM software and methods.
Big Changes Began On January 1st 2020
On January 1st 2020… CMS expanded the Remote Patient Monitoring CPT Codes. Unfortunately, the final report is 2,745 pages long!
Unless you have the time and you love reading endless pages of CPT codes, you’re going to want to read our brief summary below.
Because our RPM software (optimize.health) works in compliance with the latest CPT codes… it’s basically required reading for us.
A quick rundown of the 2020 CPT Code changes are summarized below. The 2020 expansion represents further opportunity for practices to benefit from additional clinical outcomes, while simultaneously generating additional revenue.
- CMS finalized the allowance of general supervision for RPM services (we now have a clear, set in stone, list of what you can and can’t do).
- There is also a newly created RPM add-on code for each additional 20 minutes of treatment management.
Alone, these two developments are truly significant in the way that remote monitoring services may be conducted and billed going forward.
In addition, CMS finalized a number of other changes that help to broaden digital medical services.
Not only does this create an easier way for clinics to get reimbursed, it also allows clinics to take on more RPM clients because most of the tasks can be handled by entry-level assistants, RN’s and automated with the help of a solid RPM system.
Want To Dive Deeper Into The 2020 CPT Codes Without Reading 2,745 Pages?
We broke down the more important pieces right here:
On Chronic Care Remote Physiologic Monitoring:
- CPT code 99453 covers remote monitoring of physiological parameters such as blood pressure, weight and pulse oximetry, as well as the initial setup and educating patients about how to use the equipment. It offers reimbursement for work involved in on-boarding new patients and it can be billed once per episode of care.
- CPT code 99454 deals with the devices’ supply of daily recordings and/or programmed alerts to the patient over a 30-day period. This can be billed every 30 days.
- In 2020 CPT code 99457 will serve as a base code that describes the first 20 minutes of the treatment management services and uses a new add-on (CPT code 99458) to describe subsequent 20 minute intervals of service. The new code descriptors for CY 2020 are:
- CPT code 99457 “Remote physiologic monitoring treatment management services, clinical staff/physician/other qualified health care professional time in a calendar month requiring interactive communication with the patient/caregiver during the month; initial 20 minutes”
- CPT code 99458 “Remote physiologic monitoring treatment management services, clinical staff/physician/other qualified health care professional time in a calendar month requiring interactive communication with the patient/caregiver during the month; additional 20 minutes”
- CMS agreed that the new CPT code 99458 requires the same work and intensity as the RPM base code (99457). Therefore, CPT code 99458 will be paid out at approximately the same level as the RPM base code.
- CMS also finalized their proposal to designate both CPT code 99457 and CPT code 99458 care management codes as defined in § 410.26(b)(5). Services can be furnished under general supervision so the “physician or other qualified healthcare professional supervising the auxiliary personnel need not be the same individual treating the patient more broadly.”
- CMS did not define what is meant by “physiologic parameters”, “digitally transmitted data” (as opposed to patient-reported data), “medical device,” and “interactive communication.” Given the numerous questions raised by commenters, CMS will “plan to consider these and other questions related to RPM in future rule-making.”
On Transitional Care Management (TCM) Services:
- CMS finalized their proposal to allow concurrent billing of several care management codes including CPT code 99091 (remote patient monitoring).
On Consent for Communication Technology-Based Services (CTBS):
- CMS finalized a policy to permit a single consent to be obtained for multiple CTBS or interprofessional consultation services.
- CMS also acknowledged stakeholder feedback associated with cost sharing for CTBS and interprofessional consultation services. However, they reiterated lack of statutory authority to eliminate cost sharing.
On Principle Care Management (PCM) Services:
- CMS is finalizing the creation of Principal Care Management (PCM) services, that describe care management services for one serious chronic condition. A qualifying condition will typically be expected to last between 3 months and 1 year, or until the death of the patient; a “disease-specific” care plan will be more appropriate than a comprehensive care plan; an initiating visit and the patient’s verbal consent are necessary.
- CMS agreed that there is no duplication of care management between PCM and other care management services, particularly convinced that “RPM services are distinct from PCM and could be billed concurrently by the same practitioner for the same beneficiary provided that the time is not counted twice.”
Online Digital Evaluation Service (e-Visit):
- CPT Codes 98970, 98971, and 98972. CPT originally deleted two codes and replaced them with six new “non-face-to-face” codes to describe patient-initiated digital communications that require a clinical decision otherwise typically provided in the office. CPT codes 99421-99423 are for practitioners who can independently bill E/M services while CPT codes 98970-98972 are for practitioners who cannot independently bill E/M services. The statutory requirements that govern the Medicare benefit are specific regarding which practitioners may bill for E/M services. Thus, when codes are established that describe E/M services that fall outside the Medicare benefit category of the practitioners who may bill for that service, CMS typically creates parallel HCPCS G-codes with descriptions that refer to the performance of an “assessment” rather than an “evaluation.” Therefore, for CY 2020, CMS proposes separate payment for online digital assessments via three HCPCS G-codes that mirror the RUC recommendations for CPT codes 98970-98972:
- HCPCS code G2061 (Qualified non physician healthcare professional online assessment and management, for an established patient, for up to seven days, cumulative time during the 7 days; 5-10 minutes);
- HCPCS code G2062 (Qualified non physician healthcare professional online assessment and management service, for an established patient, for up to seven days, cumulative time during the 7 days; 11-20 minutes); and
- HCPCS code G2063 (Qualified nonphysician qualified healthcare professional assessment and management service, for an established patient, for up to seven days, cumulative time during the 7 days; 21 or more minutes).
On Chronic Care Management (CCM) Services:
- CMS did not finalize their proposal to create HCPCS codes GCCC1, GCCC3 or GCCC4, over concerns that the introduction of temporary G codes replacing most of the CCM codes would create administrative burdens. However, they did finalize GCCC2 (the add-on for non-complex CCM clinical staff time), henceforth referred to as G2058.
- Beginning in CY 2020, for PFS billing purposes for CPT codes 99487 and 99489, they will interpret the code descriptor “establishment or substantial revision of a comprehensive care plan” to mean that a comprehensive care plan is established, implemented, revised, or monitored. This will allow for consistency in the care planning service element of complex CCM and non-complex CCM services provided by clinical staff.
- The new language will read: “The comprehensive care plan for all health issues typically includes, but is not limited to, the following elements:
- Problem list
- Expected outcome and prognosis
- Measurable treatment goals
- Cognitive and functional assessment
- Symptom management
- Planned interventions
- Medical management
- Environmental evaluation
- Caregiver assessment
- Interaction and coordination with outside resources and practitioners and providers
- Requirements for periodic review
- When applicable, revision of the care plan”
- The new language will read: “The comprehensive care plan for all health issues typically includes, but is not limited to, the following elements:
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