On July 29, 2019 the CMS issued their new proposed rules for the 2020 Medicare Physician Fee Schedule which included several significant changes and additions to the Remote Patient Monitoring services.
Medicare has taken significant steps towards accelerating the adoption of remote patient care with the creation of new RPM codes CTP 99457, 99454 and 99453 in January 2019. From the CMS’s proposal for 2020, it is clear that the CMS continues to support and expand on the non face-to-face care adoption push by adding new codes, add-on reimbursements and wider administration eligibility. The most impactful 2020 proposed changes are discussed below:
New RPM Code for Extra Minutes
In 2019 the CMS introduced a new CPT code 99457 that reimburses for remote physiological monitoring treatment management services. It requires 20 minutes or more of clinical staff, a physician or other qualified healthcare professional’s time in a calendar month as well as interactive communication with the patient or caregiver during that month. The code pays $54 per patient per calendar month.
The newly proposed code 9945X would then reimburse for time beyond the initial 20 minutes covered by code 99457, effectively giving providers the opportunity to be paid more for patients who require more care time, significant monitoring and interaction during a particular month. The newly proposed 9945X code is to pay $26.31, so for a patient who requires 40 minutes or more during a month the total reimbursement would be $77.85.
Change from Direct Supervision to General Supervision
The CMS proposed changing the supervision requirement for “incident to” billing of clinical staff time spent from direct to general. This proposal is relaxing the requirement of clinical staff being in the same location as the billing practice/practitioner, to clinical staff being able to monitor and interact with patients from a different location than the practitioner that bills for it. This change echoes the rules of the Chronic Care Management program where general supervision has already been allowed. This change will give practitioners who are interested in remote patient monitoring the option to outsource such a service or the clinical staff needed to operate it.
New CCM Category Proposed for Patients with Only One Chronic Condition
The CMS recognizes that the current CCM program bypasses patients with a single yet a serious, high risk condition and proposes to create a new Principal Care Management (PCM) program category with two new CPT codes. Under the PCM program, practitioners would be reimbursed, under the same requirements as for CCM, for a non face-to-face care of these single chronic condition patients. The following non-complex care codes are proposed:
GPPP1 30 minutes of physician time per month at $74.24 per patient
GPPP2 30 minutes of clinical time per month at $42 per patient (the same as CPT 99490). This new category mirrors the requirements for RPM which already includes a single health condition patients. Although RPM codes pay more than CCM codes, this new program would allow practitioners with established RPM services to potentially combine their RPM minutes that do not meet the time requirements with CCM minutes for such patients and maximize their reimbursement allowance.
New Codes Proposed for Additional CCM Time
Practitioners offering Chronic Care Management Services, which might or might not include RPM, currently have 3 dedicated CPT codes available: CPT 99490 for 20 minutes of CCM time, CPT 99487 for 60 minutes of COMPLEX CCM time and CPT 99489 for each 30 minutes of additional CCM time.
The CMS recognizes that some patients might require additional time for non-complex care and is proposing to add new CPT codes that would reimburse practitioners beyond the initial 20 minutes of non-complex care under CPT 99490. This proposal is in line with the creation of the new RPM code 9945X mentioned earlier.
The CCM proposes to replace the CPT 99490 with two new General Care Management codes (G-codes): GCCC1: 20 minute of initial clinical staff time per month at $42 per patient and GCCC2: additional 20 minute of clinical staff time per month at $31.25 per patient.
With these new codes, practitioners would receive more reimbursement where a patient required care beyond the initial 20 minute currently covered by the CPT 99490 so for a patient who received 40 minute on non-complex care the practitioner would bill a total of $73.52. As remote patient monitoring falls under the non face-to-face care category, any remote patient monitoring activity is also a CCM activity. Adding more CCM codes ultimately benefits practitioners with an established RPM program as it allows them to combine RPM minutes that didn’t meet the time minimum for an RPM code with CCM minutes and bill under CCM, albeit a lesser amount than they would have billed under an RPM code.
Overall, the newly proposed changes are positive and will provide for an opportunity to increase reimbursement opportunities for practitioners with remote patient monitoring programs in 2020.
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Source: The CMS website