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2024 Proposed Medicare Physician Fee Schedule

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7 Key Takeaways for Remote Monitoring Services

On July 13, 2023, the Centers for Medicare & Medicaid Services (CMS) released the Proposed Medicare Physician Fee Schedule for 2024. In this new proposed rule, CMS has included numerous changes and clarifications to remote monitoring and care management services. Below are some of the key highlights providers and practices should be aware of regarding Remote Physiologic Monitoring (RPM) and Remote Therapeutic Monitoring (RTM):

Decrease in Physician Conversion Factor

Under the new proposal, physicians would see a decrease in the conversion factor by 3.36% on January 1, 2024, reducing it from $33.8872 to $32.7476. This reduction could impact reimbursement rates for services, and providers must be prepared for potential financial implications.

Remote Monitoring for Established Patients

Under the proposed rule, CMS reiterates that with the conclusion of the Public Health Emergency (PHE), RPM and RTM services may only be provided to established patients. However, patients who initially received remote monitoring services during the PHE, when this requirement was waived, are now considered established patients. This distinction is critical for providers to understand when determining eligibility for remote monitoring services.

16-Days Requirement

CMS maintains the requirement that remote monitoring must take place over a minimum of 16 days within a 30-day period.

Billing RPM and RTM

The new rule allows for flexibility in selecting the right mix of care management services. RPM or RTM (but not both) may be billed concurrently with code sets for Chronic Care Management, Transitional Care Management, Behavioral Health Integration, Principal Care Management, and Chronic Pain Management services, as long as no time associated with a service is counted twice for another service. This option provides opportunities for more comprehensive care management for eligible patients.

RPM and RTM Furnished Separately from Global Services Payment for Surgery

CMS clarifies that RPM and RTM services may be furnished and reimbursed separately from the global services payment for surgery, if all other requirements for the global service and any other service during the global period are met.

RPM and RTM Reimbursement for FQHCs and RHCs

CMS proposes to allow RPM and RTM reimbursement for Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) by introducing HCPCS code G0511. This potential expansion of reimbursement options can benefit patients in underserved areas an improve access to remote monitoring services.

RPM as “Primary Care Services” Under the Medicare Shared Savings Program

CMS proposes to classify RPM CPT codes 99457 and 99548 as primary care services under the Medicare Shared Savings Program (MSSP) for determining beneficiary assignments to an MSSP Accountable Care Organization (ACO). This change could have implications for ACOs, and providers participating in MSSP and may encourage more comprehensive patient care through RPM.

The 2024 Proposed Medicare Physician Fee Schedule introduces significant changes and opportunities for remote monitoring and care management services. Providers and practices should carefully review the proposed rule to understand its impact on reimbursement rates and the eligibility criteria for remote monitoring services. Adapting these changes and taking advantage of the opportunities presented can lead to improved patient care and outcomes in the evolving healthcare landscape.

For more information or to review the 2024 Medicare Physician Fee Schedule Proposed Rule visit the official CMS website.

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