2018 Medicare Remote Monitoring Reimbursement Guidelines
- Feb 27, 2018
- 6 min read
We learned earlier this year, that effective January 1, 2018, the Medicare program will pay providers for remote patient monitoring (RPM) services billed under CPT code 99091.
In summary, the service is currently defined as the:
“collection and interpretation of physiologic data (e.g., ECG, blood pressure, glucose monitoring) digitally stored and/or transmitted by the patient and/or caregiver to the physician or other qualified health care professional, qualified by education, training, licensure/regulation (when applicable) requiring a minimum of 30 minutes of time.”
The code is not newly created category. What Medicare did was to unbundle the code from other services, and designate it as a separately payable service.
Currently, CPT code 99091 fails to optimally describe RPM services, such as the OnePrevent system, due primarily to the age of the code. The American Medical Association’s (AMA) CPT Editorial Panel is working on developing new codes. We are doing what we can to understand the new billing opportunities under Medicare. More will be coming out shortly. Until the new codes are available
Core requirements to bill Medicare for RPM services under CPT 99010:
The practitioner must get the patient’s consent for RPM services and document it in the patient’s medical record.
For new patients or patients not seen by the practitioner within one year prior to billing RPM, the practitioner must first conduct a face-to-face visit with the patient (e.g., an annual wellness visit or physical). E/M services levels 2 through 5 (CPT codes 99212 through 99215) should qualify for this face-to-face visit. Transitional care management (TCM) services should also qualify. However, services that do not involve a face-to-face visit by the billing practitioner or which are not separately payable under Medicare (e.g., online services, telephone and other E/M services) would not qualify as an initiating visit.
CPT 99091 should be reported no more than once in a 30-day period per patient.
The service must include the physician or other qualified health care professional time involved with data accession, review and interpretation, modification of care plan as necessary (including communication to patient and/or caregiver), and associated documentation.
CPT 99091 can be billed once per patient during the same service period as chronic care management (CCM) services (CPT codes 99487, 99489, and 99490), TCM services (CPT codes 99495 and 99496), and behavioral health integration services (CPT codes 99492, 99493, 99494, and 99484). This is allowed because CMS recognizes the kind of analysis involved in furnishing RPM services is complementary to CCM and other care management services. However, time spent furnishing these services cannot be counted towards the required time for both RPM and CCM codes for a single month (i.e., no double counting).
Because RPM services are not considered telehealth services under Medicare, the patient can be at his/her home, and need not be in a rural area or qualifying originating site.
Below are a couple of other article links describing reimbursement for remote patient monitoring.
Dan's Notes
Effective January 1, 2018, the Medicare program will pay providers for RPM services billed under CPT code 99091.
CPT 99091 is not a newly-created code. Instead, Medicare “unbundled” it and designated it as a separately-payable service. Regardless of how CMS accomplished it, the final result is clear: Medicare will now pay providers a monthly fee for delivering RPM services.
After considering the differences, CMS elected to keep CPT 99090 “bundled” and not allow its use for separate payment.
It is true that CPT 99091 fails to optimally describe how RPM services are furnished using current technology. This may be due to the fact that the code description is years old and has never before been a separately payable service. The AMA’s CPT Editorial Panel is currently working on new codes intended to more accurately describe remote monitoring. But providers, patients, and CMS itself did not want to wait until those new codes were developed. Until new codes are published and approved by CMS, providers should use the current CPT 99091 for billing RPM services.
Here are some of the core requirements to bill Medicare for RPM services under CPT 99010:
The practitioner must get the patient’s consent for RPM services and document it in the patient’s medical record.
For new patients or patients not seen by the practitioner within one year prior to billing RPM, the practitioner must first conduct a face-to-face visit with the patient (e.g., an annual wellness visit or physical). E/M services levels 2 through 5 (CPT codes 99212 through 99215) should qualify for this face-to-face visit. Transitional care management (TCM) services should also qualify. However, services that do not involve a face-to-face visit by the billing practitioner or which are not separately payable under Medicare (e.g., online services, telephone and other E/M services) would not qualify as an initiating visit.
CPT 99091 should be reported no more than once in a 30-day period per patient.
The service must include the physician or other qualified health care professional time involved with data accession, review and interpretation, modification of care plan as necessary (including communication to patient and/or caregiver), and associated documentation.
CPT 99091 can be billed once per patient during the same service period as chronic care management (CCM) services (CPT codes 99487, 99489, and 99490), TCM services (CPT codes 99495 and 99496), and behavioral health integration services (CPT codes 99492, 99493, 99494, and 99484). This is allowed because CMS recognizes the kind of analysis involved in furnishing RPM services is complementary to CCM and other care management services. However, time spent furnishing these services cannot be counted towards the required time for both RPM and CCM codes for a single month (i.e., no double counting).
Because RPM services are not considered telehealth services under Medicare, the patient can be at his/her home, and need not be in a rural area or qualifying originating site.
Entrepreneurs and companies offering RPM technologies should take steps now to understand the new billing opportunities under Medicare. With the forthcoming new CPT codes for more RPM services, this looks to be an area of significant upside potential over the coming years. Hospitals and providers using telehealth and non-face-to-face technologies to develop patient population health and care coordination services should take a serious look at RPM services billing opportunities, and keep abreast of developments that can drive recurring revenue and improve the patient care experience.
https://www.cms.gov/Newsroom/MediaReleaseDatabase/Fact-sheets/2017-Fact-Sheet-items/2017-11-02.html
"We are also finalizing separate payment for CPT code 99091, which describes certain remote patient monitoring, for CY 2018. Lastly, we will consider the stakeholder input we received in response to the proposed rule’s comment solicitation on how CMS could expand access to telehealth services, within the current statutory authority."
Downloads from the OnePrevent system can
increase patient compliance, lead to better patient care,
improve healthcare outcomes and assist in meeting reimbursement documentation requirements.
OneEvent's product and mobile services have download capabilities via dashboard remote monitoring technology.
Prior to the 2018 change…
9. Is Medicare now paying separately under the PFS for remote patient monitoring services described by CPT code 99091 or similar CPT codes?
CPT 99091 continues to be bundled with other services for payment under the PFS. As per CPT guidance, CPT codes 99090, 99091 and other codes cannot be billed during the same service period as CPT 99490. However as discussed in the CY 2015 PFS final rule (79 FR 67727), analysis of patient-generated health data and other activities described by CPT 99091 or similar codes may be within the scope of CCM services, in which case these activities would count towards the minimum minutes of qualifying care per month that are required to bill CCM services.
But in order to bill CCM services, such activity cannot be the only work that is done—all other requirements for billing CCM must be met in order to bill the appropriate code, and time counted towards billing CCM services cannot also be counted towards billing other codes.
CPT1
Description
Medicare Reimbursement
2014 Fee Schedule (subject to change)2
99090
Analysis of clinical data stored in computers
bundled*
99091
Physician/health care professional collection and interpretation of physiologic data stored/transmitted by patient/caregiver
bundled*
*Medicare considers 99090 and 99091 as bundled into payment for other basic services (eg, an office visit provided the same day or other services incident to the service provided). Therefore, Medicare does not make separate payment for 99090 and 99091. Providers should consider contacting commercial payors as they may reimburse for the service.
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