On July 13th, the Center for Medicare and Medicaid Services (“CMS”) released the 2022 Medicare Physician Fee Schedule Proposed Rule (“2022 Proposed Rule”). This is the second step of the annual cycle for updating which healthcare services are reimbursable by Medicare, and to what extent:
- Q1 2021: The Digital Medicine Payment Advisory Group of the American Medical Association (AMA) develops and recommends new Current Procedural Terminology (CPT) codes for digital healthcare services.
- Q3 2021: CMS reviews utilization data of existing CPT codes, new medical literature, and the AMA’s recommendations. CMS publishes its annual Proposed Rule and solicits feedback from healthcare industry stakeholders in the form of public comments. (This is where we are now.)
- Q4 2021: CMS synthesizes feedback and publishes its annual Final Rule to the Federal Register.
Impact on Remote Physiological Monitoring (RPM)
The 2022 Proposed Rule did not put forward any changes to the five RPM CPT codes released since 2018: 99091, 99453, 99454, 99457, 99458. This stability is welcomed and exciting. Practices who have adopted RPM in its first few years can focus their efforts on improving the health of their chronic patients on RPM, and expanding their programs to all who need RPM. Practices who’ve yet to adopt RPM should feel comfortable that RPM is here to stay.
New Reimbursement for Remote Therapeutic Monitoring (RTM)
The 2022 Proposed Rule does expand CMS reimbursement into a new area of remote monitoring - Remote Therapeutic Monitoring (RTM). CMS has proposed that RTM should have reimbursement parity with RPM, and the language of the RTM codes resembles that of the RPM codes:
Setup and patient education (one code):
- CPT code 989X1 - Remote therapeutic monitoring (e.g., respiratory system status, musculoskeletal system status, therapy adherence, therapy response); initial setup and patient education on use of equipment
Device supply with data / programmed alerts (two codes):
- CPT code 989X2 - Remote therapeutic monitoring (e.g., respiratory system status, musculoskeletal system status, therapy adherence, therapy response); device(s) supply with scheduled (e.g., daily) recording(s) and/or programmed alert(s) transmission to monitor respiratory system, each 30 days
- CPT code 989X3 - Remote therapeutic monitoring (e.g., respiratory system status, musculoskeletal system status, therapy adherence, therapy response); device(s) supply with scheduled (e.g., daily) recording(s) and/or programmed alert(s) transmission to monitor musculoskeletal system, each 30 days
Monitoring and interactive communication (two codes):
- CPT code 989X4 - Remote therapeutic monitoring treatment management services, physician/other qualified health care professional time in a calendar month requiring at least one interactive communication with the patient/caregiver during the calendar month; first 20 minutes
- CPT code 989X5 - Remote therapeutic monitoring treatment management services, physician/other qualified health care professional time in a calendar month requiring at least one interactive communication with the patient/caregiver during the calendar month; each additional 20 minutes
A close reading of the codes’ language indicates a few important differences from RPM:
- RTM is constrained to two condition categories: While RPM does not constrain reimbursability to specific condition categories, RTM does: respiratory and musculoskeletal only.
- RTM allows non-physiological data: While RPM requires physiological data, RTM allows for non-physiological data salient to a patient’s condition, e.g. therapy adherence, therapy response.
- RTM allows self-reported data: While RPM requires automatic data transmission from a medical device, RTM can be self-reported.
- Physical therapists can furnish RTM: While RPM allows general supervision for “incident to” billing, it is an E/M code, which physical therapists cannot bill to; RTM are classified as general medicine codes.
Finally, the CMS offered a hypothetical example of how RTM might be used under the Proposed Rule:
An asthmatic patient is prescribed a rescue inhaler equipped with an FDA-approved medical device that monitors when the patient uses the inhaler, how many times during the day the patient uses the inhaler, how many puffs/doses the patient uses each time, and the pollen count and environmental factors that exist in the patient’s location at that time. This is non-physiologic data. The data is then used by the treating practitioner to assess the patient’s therapeutic response and adherence to the asthma treatment plan. This can enable the practitioner to better determine how well the patient is responding to the particular medication, what social or environmental factors affect the patient’s respiratory system status, and what changes could be made to improve the patient’s health.
This illustrative use case is helpful, and only scratches the surface of what might be possible with RTM. All stakeholders involved in the remote monitoring space should feel encouraged by the continued investment into remote monitoring, with the number and value of reimbursable codes set to double come January 1, 2022.