As the adoption of telehealth, remote monitoring, and connected care technologies continues to increase, it’s important for healthcare leaders to stay on top of the latest updates in telehealth reimbursement. 

Some of the most significant updates come from the Centers for Medicare & Medicaid Services (CMS), which released its final rule for Medicare payments under the Physician Fee Schedule (PFS) in 2024. Let’s delve into the eight key updates impacting telehealth and remote patient monitoring (RPM) services:

1. Established Patient Requirement: A fundamental change concerns new patients seeking RPM services. Before initiating these services, a new patient evaluation and management (E/M) or similar service is now mandatory. This ensures a clear care plan is established during an in-person visit. However, exceptions exist for patients who utilized RPM during the Public Health Emergency (PHE) as they already have an established patient-provider relationship. Additionally, this established patient rule doesn’t apply to remote therapeutic monitoring (RTM) reimbursement.

2. 16-Day Data Collection for RPM: The billing guidelines for RPM data collection have been revised. Now, healthcare providers need to collect data for at least 16 of the 30-day episode of care period, excluding calendar month days, for CPT codes 99453 and 99454. This clarifies the data collection requirements for accurate reimbursement of these specific codes.

3. Clarity on RPM/RTM “Time Spent”: CMS has provided further clarity regarding time spent billing guidelines for specific CPT codes. Codes 99457, 99458, 98980, and 98981, representing “time spent” for treatment management, are not subject to the 16-day data collection requirement. They maintain their existing billing guideline of a 30-day calendar month.

4. One Provider for RPM/RTM Billing: A significant update concerns the number of providers permitted to bill for RPM and RTM services. According to the new guidelines, only one provider can bill for either RPM device codes (99453 and 99454) or RTM codes (98976, 98977, 98980, and 98981) within a 30-day episode of care. This means the provider who submits the claim first will be reimbursed, whereas subsequent claims from other providers for the same patient during that period will be denied.

5. Concurrent Billing with Other Services: Reimbursement for RPM and RTM cannot be combined with similar services within the same month. However, specific services like Chronic Care Management (CCM), Transition Care Management (TCM), Behavioral Health Integration (BHI), Principal Care Management (PCM), and Chronic Pain Management (CPM) can be billed concurrently with either RPM or RTM.

6. Billing During Global Surgery Periods: The 2024 Physician Fee Schedule clarifies the permissible timeframe for billing RPM/RTM services during a surgical global period, defined as the time during which a physician cannot bill for related office visits. Now, if the billing provider for RPM or RTM services is different from the provider receiving the global payment, these services can be billed. Additionally, if RPM or RTM services were already in place before the surgery, CMS allows payment outside the surgical global period.

7. FQHCs and RHCs Gain Reimbursement: This update presents new opportunities for Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs). They can now receive reimbursement from CMS for either RPM or RTM services (not both) when billed alongside Care Management CPT code G0511. This code can be billed multiple times per calendar month, offering additional financial support for these healthcare facilities.

8. New Cost Fee Structure: The final update concerns changes to the cost fee structure. While the specific details are outside the scope of this article, it’s important to be aware that individual CPT code reimbursement rates for RPM, CCM, and RTM have been slightly adjusted.

These updates highlight the ongoing evolution of telehealth and remote patient monitoring regulations. By staying informed about these changes, healthcare providers and facilities can ensure they are delivering compliant and reimbursable care to patients while optimizing their practice efficiency.

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The post State Medicaid & CHIP Telehealth Toolkit appeared first on mTelehealth.

February 15, 2024 Anne Dwyer

This month, CMS released an updated State Medicaid and CHIP Telehealth Toolkit consolidating information from previous toolkits and providing additional guidance – as required by the Bipartisan Safer Communities Act – on issues from billing best practices to strategies for using telehealth in schools.

In addition to FAQs on issues such as benefit flexibility, financing, workforce, managed care, and quality reporting, the comprehensive updated toolkit also includes information on strategies for delivering specific services via telehealth to different populations. This includes employing telehealth to improve health equity, delivering services to specific populations, including children and youth, and using telehealth to deliver maternal and behavioral health services.

Highlighted state best practices from the toolkit related to telehealth and behavioral health include:

• Colorado, which has a dedicated website for school-based services that includes procedure codes for telehealth, and allows for the telehealth delivery of certain services including behavioral health.
• Iowa, which has employed targeted promotion of telehealth to members and providers in counties with lower utilization of behavioral health care, including utilization by geography and race/ethnicity to identify and address barriers.
• North Carolina, which during the COVID-19 public health emergency temporarily permitted Medicaid providers to provide perinatal care, maternal support services, and postpartum depression screening via telehealth and in 2023 permanently permitted the use of telehealth for prenatal and postpartum visits.
• Oregon, which leveraged the State Directed Payments Option under managed care to create an enhanced payment rate increase for behavioral health services delivered by culturally- and/or linguistically-specific behavioral health providers, including services delivered via telehealth.

The toolkit also includes strategies for delivering services via telehealth to address behavioral health provider shortages including leveraging Certified Community Behavioral Health Clinics, community-based mobile crisis units, and the Collaborative Care Model with telepsychiatry. For example, the toolkit notes that states may submit a request for a 90/10 enhanced Medicaid match for a number of IT initiatives to support mobile crisis units, including the provision of cell phones or iPads to state-staffed mobile crisis teams to facilitate telehealth with a clinic at another location during a crisis intervention.

The updated toolkit including additional state best practices and strategies as well as other information such as a state checklist, a state Medicaid telehealth assessment/action plan, and telehealth communication strategies can be found here.

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Executive Summary

Digital health advocates believe remote monitoring—the use of digital technologies to collect and relay patient data to health care professionals—has the potential to transform disease management, health outcomes, and patient care, especially for individuals with multiple chronic conditions who lack convenient access to providers. Medicare, most state Medicaid agencies, and many private health insurance plans cover remote monitoring services.

For the purposes of this report, we define remote monitoring as an umbrella term for remote physiologic monitoring (RPM) and remote therapeutic monitoring (RTM). RPM refers to the monitoring of physiologic data—such as weight, blood glucose, or blood pressure—while RTM refers to the monitoring of patients’ self-reported non-physiologic data, such as pain levels or medication adherence. Currently, the Centers for Medicare & Medicaid Services (CMS) limits RTM reimbursement to cases involving the respiratory system, musculoskeletal system, and cognitive behavioral therapy.

Although the percentage of patients using RPM remains relatively low (594 monthly claims per 100,000 Medicare enrollees in 2021), the use of RPM increased among Medicare beneficiaries more than sixfold from 2018-2021. In part, this increase was due to CMS’ expanded coverage rules during the COVID-19 public health emergency. Thirty-four state Medicaid programs covered RPM services as of March 2023; however, many Medicaid programs restrict RPM use in some way. RTM uptake has also steadily increased since its introduction in 2022, yet billing and documentation requirements can hinder its widespread adoption.

The evidence base on remote monitoring, particularly for RPM tools, is growing. Yet some policy experts cite a lack of robust evidence on the optimal use of remote monitoring, including its duration and target patient groups. In the absence of such evidence, these experts question whether we are effectively “rightsizing” the use of these services. Underuse could limit access to beneficial care, while overuse could unnecessarily increase spending in federal health care programs. Additionally, providers cite the need for tools—such as generative artificial intelligence (AI)—to manage streams of data, otherwise the volume of patient-generated information can become overwhelming and unmanageable.

Over the past year, the Bipartisan Policy Center undertook an extensive effort to develop evidence-based, federal policy recommendations for the appropriate use and coverage of remote monitoring services. BPC assessed patients’ access to and use of remote monitoring technologies and their impact on health outcomes and cost. We conducted a series of interviews and hosted a private roundtable with health policy experts, federal officials, technology leaders, medical providers, payers, consumers, and academics to gain insight into the opportunities and challenges regarding remote monitoring.

This report looks broadly at ways to improve the use of remote monitoring services, ensure equitable access to these services across populations, and enhance data security and privacy standards. Now is the time for payers and providers to refine their approach and maximize appropriate adoption for patients who stand to benefit from remote monitoring.

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The next generation of healthcare will have a face that will likely be much different than anything seen before. The push to rapid innovation, especially in the wake of COVID-19 pandemic, resulted in solutions that provided new outlook in the way healthcare is supervised. As all the industries adjusted to working remotely, healthcare has been more benefitted than most with this shift, where doctors and other clinicians turned to emerging technological solutions in order to keep up with growing demand for healthcare services while keeping patients safe.

Remote Patient Monitoring And Telehealth: The Growth Story

Telehealth had already been a prevailing practice that was beneficial for patients located in remote areas. It was swiftly leveraging technology, providing on-demand consultations to patients. However, the epic pandemic brought its awareness at great extent. It became the silver lining, as government-imposed lockdowns and transmission of the virus restricted physical human interactions. Since in-person visits had to be avoided due to the significant increased risk to patients, telehealth services were rapidly adopted which greatly helped in expanding the access to healthcare. The global telehealth market is likely to witness a growth rate of nearly 24% through 2023-2035.

New solutions to telehealth not only helped healthcare providers to see patients through, but also provided patients with faster, more accurate and complete care. Solutions did not only just expand to texts, phone calls, image forwarding, video consultations, but went further to remote patient monitoring and robust patient health portals. Remote patient monitoring emerged as a significant strategy for telehealth globally, creating robust opportunities for companies that largely dealt outside of the traditional healthcare technology. As per our analysis, the global remote patient monitoring market is estimated to cross a revenue of USD 36 Billion by the end of 2033.

Challenges

Technological innovations have fostered the potential of telehealth. The most effective benefit of telehealth services is the convenience and ease of access, for both healthcare providers and patients. With leveraging technology such as smart wearables and smart home communication systems, telehealth services have improved in the quality and quantity of care provided to consumers. Smart devices provide direct and relevant patient data, and allow constant daily remote monitoring, resulting in obvious benefits to patient care. Along with improved quality, it also improves patient behavior by creating a system where people are more engaged with and responsible for their health. It has also given people a sense of assurance and comfort that someone is watching over their health and well-being on a daily basis.

The Changing Face Of Healthcare

The healthcare industry, today, has created an environment where consumers can demand quality services, lower costs, and easy and convenient access to services. Telehealth has emerged as an innovative and valuable strategy to provide quality healthcare services at lower costs with an easy and effective accessibility. As the most straight-forward initiatives toward revolutionizing digital health, the telehealth market is expanding as new companies are emerging with new and more innovative solutions to improve the potential of telehealth services. Remote patient monitoring is the most effective trend which has changed the competitive and relationship dynamics of telehealth industry, and will continue to be very active as the industry expands with new solutions coming in together. Some of the recent trends that is predicted to shape the future of telehealth services are:

• Telemedicine program in the United States are rendered by over 51% healthcare organizations.
• Telehealth improves the service quality of the treatment provided to the patients, claims about 50% of the healthcare organizations globally.
• While deciding for treatment, more than 55% of the patients feel that their involvement has increased significantly in the decision-making process as a result of the benefits associated with telehealth.

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In November 2023, CMS issued final rules for the 2024 Medicare Physician Fee Schedule (MPFS) and the 2024 Medicare Outpatient Prospective Payment System (OPPS). Both of these rules contained finalized policy proposals that will impact rural health clinics (RHCs) beginning in January 2024:

• Telehealth Flexibilities
• Medicare Coverage of Marriage and Family Therapists and Mental Health Counselor Services
• Intensive Outpatient Program (IOP) Services Billable in RHC Under Special Payment Rule
• Expansion of RHC Care Management Services
• Definition Change to Nurse Practitioner

Telehealth Flexibilities

CMS has officially extended some telehealth flexibilities that were allowed during the public health emergency (PHE) to continue through December 31, 2024. Specifically, CMS finalized the following:

• RHCs may be reimbursed for telehealth services utilizing CPT code G2025
• Removed the originating and geographic site requirements, which allows patients to be located in any location during the telehealth visit. This would include the patient’s home. It should be noted that telehealth services are to be provided during the RHC’s operating hours
• Delayed the in-person requirement for mental health visits performed via telehealth
• Extended audio-only coverage allowance for telehealth services
• Expanded the list of telehealth distant site providers to include Marriage and Family Therapists (MFTs) and Mental Health Counselors (MHCs)

New Billable RHC Provider Types

MFTs and MHCs have now been officially added as qualified RHC provider types. An MHC is an individual who:

• “(A) possesses a master’s or doctor’s degree which qualifies for licensure or certification as a mental health counselor, clinical professional counselor, or professional counselor under the State law of the State in which such individual furnishes the services described in paragraph (3);
• (B) is licensed or certified as a mental health counselor, clinical professional counselor, or professional counselor by the State in which the services are furnished;
• (C) after obtaining such a degree has performed at least two years of clinical supervised experience in mental health counseling; and
• (D) meets such other requirements as specified by the Secretary.”

Effective January 1, 2024, MFTs and MHCs will be able to generate Medicare encounters and be reimbursed for those services at the RHC’s all-inclusive rate (AIR). MFTs and MHCs also have the ability to meet the requirement that a provider must be available to provide care to patients at all times the clinic is open.

Intensive Outpatient Program (IOP) Services

IOP services are outpatient mental health services that are designed for patients who require more complex mental health care than would be able to be accomplished during a typical office visit, but not so severe that an inpatient mental service would be required. These services are intended for patients with acute mental illnesses such as depression and substance abuse disorders who require a higher level of care. In its proposal, CMS specified the services eligible to be provided and reimbursed under an IOP may include:

• Individual and group therapy with physicians, psychologists, and other mental health professionals as available under state law
• Occupational therapy
• Furnishing of drugs and biologicals for therapeutic purposes that are not self-administered
• Family counseling (as part of treatment of the patient’s condition)
• Patient training and education
• Individualized activity therapies
• Diagnostic services
• Other related services for diagnosis and active treatment intended to improve or maintain the patient’s condition and function

To quality a patient for IOP services, a physician is required to certify that a patient needs behavioral health services for at least nine, but no more than 19 hours per week. That certification must be completed by a physician at least once every other month for the patient to continue to qualify for services and the plan of care must demonstrate that the patient:

• Requires at least nine hours of therapeutic services per week
• Is likely to benefit from coordinated services rather than individual sessions of outpatient treatment
• Does not need 24-hour care
• Has a support system outside of the IOP
• Has received a mental health diagnosis
• Is not a danger to themselves or others
• Has the cognitive and emotional ability to tolerate the IOP

IOP services will not be reimbursed at the RHC’s AIR, but rather under a special rule that would allow for a flat payment of approximately $280 per day. RHCs will be allowed to perform up to three services per day and to qualify for the special payment, at least one of the three services must be from Table 44 Proposed Partial Hospitalization and Intensive Outpatient Primary Services found on page 367 of the HOPPS Proposed Rule.

Because IOPs are a new service for RHCs, there is an expectation of future rulemaking outlining how services may be provided and reimbursed.

Expansion of RHC Care Management Services

Historically, RHCs have only been allowed to bill and be reimbursed for Care Management Services, including Remote Patient Monitoring, Remote Therapeutic Monitoring, or using CPT code G0511 or G0512 once per month per beneficiary. Under the new final rule, RHCs may now bill G0511 multiple times per month as long as the services rendered are “medically reasonable and necessary, meet all requirements, and not be duplicative of services paid to RHCs and FQHCs under the general care management code for an episode of care in a given calendar month.” In addition, CMS has finalized the establishment of new care management codes for Community Health Integration (CHI) and Principal Illness Navigation (PIN), which also will be billed to Medicare using the G0511 code and those services will be reimbursed as long as a qualified provider performs the service.

Definition Change to Nurse Practitioner

CMS has changed the definition of a nurse practitioner to state that an individual must “be certified as a primary care nurse practitioner at the time of provision of services by a recognized national certifying body that has established standards for nurse practitioners and possesses a master’s degree in nursing or a Doctor of Nursing Practice (DNP) doctoral degree.” This change allows individuals certified by additional certifying boards, including the American Academy of Nurse Practitioners Certification Board, American Nurses Credentialing Center Certification Program, Pediatric Nursing Certification Board, and the National Certification Corporation, to now meet the definition of a nurse practitioner as long as the other requirements are met.

These changes may result in significant operational, revenue cycle, and regulatory reimbursement impacts for RHCs beginning in January 2024. If you have any questions about the new requirements or would like assistance in evaluating the organization’s readiness and potential impact, please reach out to a professional at FORVIS.

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The 2024 Medicare Physician Fee Schedule final rule, released by the Centers for Medicare & Medicaid Services (CMS) earlier this month, extended certain telehealth-related flexibilities that were implemented during the early days of the COVID-19 pandemic. CMS issued a Fact Sheet summarizing the telehealth updates, as well as other important Medicare policy changes.

Until 2020, Medicare reimbursed for telehealth only for patients in designated rural areas, and they were required to travel to a healthcare facility to access telehealth services. Certain federal policies that expanded telehealth access during the pandemic were set to expire at the end of 2023, but they have now been extended for another year to synchronize with other provisions that were already extended until December 31, 2024 by the Consolidated Appropriations Act, 2023.

Among the newly extended flexibilities is continuing to define “direct supervision” to permit the presence and immediate availability of a supervising practitioner through real-time audio and video communications.

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On November 2, 2023, in the 2024 final rule for the physician fee schedule, the Centers for Medicare & Medicaid Services (CMS) finalized crucial policies impacting remote physiologic monitoring (RPM) and remote therapeutic monitoring (RTM) services reimbursed under the Medicare program. This article breaks down the key takeaways of the Medicare final rule 2024 to guide companies through the changes and clarifications.

Medicare Final Rule 2024: RPM Exclusive to Established Patients

The Medicare final rule 2024 emphasizes that RPM services can only be furnished to “established patients.” This distinction, reinstated after the Public Health Emergency (PHE), requires patients who started RPM services during the PHE to become “established patients.” Those initiating RPM services after May 11, 2023, must undergo an initial evaluation to qualify.

This re-establishment of the “established patient” requirement aims to maintain a structured approach to RPM services, ensuring a foundation of familiarity with the patient’s health history and treatment plan.

RTM’s Unique Position

In contrast, RTM services offer flexibility and do not mandate an “established patient” requirement. While an initial interaction evaluation is advisable, the Medicare final rule 2024 clarifies that an established patient relationship is not expressly required for RTM services, with potential future rulemaking to address nuances.

This flexibility in RTM requirements allows practitioners to adapt their approach based on the unique needs of patients, potentially streamlining the onboarding process for remote therapeutic monitoring.

Medicare Final Rule 2024 Billing for RPM and RTM 

In the Medicare final rule 2024, CMS clarified that certain remote monitoring codes necessitate at least 16 days of data collection in 30 days. Treatment management codes (99457, 99458, 98980, and 98981) do not adhere to the 16-day requirement, offering practitioners greater flexibility.

This clarification on data collection requirements ensures practitioners understand the expectations for different remote monitoring codes. It also addresses concerns raised during the rulemaking process about the potential burden of a uniform 16-day requirement across all codes.

In a given 30-day period, only one practitioner can bill RPM/RTM services for a patient, even with multiple medical devices. This clarity ensures streamlined billing processes while aligning with CMS’s emphasis on reasonable and necessary services.

In the Medicare final rule 2024, the emphasis on singular practitioner billing aims to avoid confusion and potential overlapping claims, ensuring that one healthcare professional coordinates each patient’s remote monitoring services.

Billing RTM for Assistants Under General Supervision

Physical therapists (PTs) and occupational therapists (OTs) can now bill Medicare for RTM services according to the Medicare final rule 2024. This includes those provided by their assistants (PTAs and OTAs), with the requirement of general supervision. The change facilitates broader access to RTM services within private practice settings.

These expanded billing capabilities for PTs and OTs underscore the importance of incorporating a diverse range of healthcare professionals in the delivery of remote therapeutic monitoring. It recognizes the collaborative nature of healthcare and the contributions of various team members.

Concurrent Billing with Care Management Services

According to the Medicare final rule 2024, practitioners can bill Medicare for RPM or RTM concurrently with certain care management services, avoiding double counting of time and effort. This strategic approach allows practitioners to tailor patient care management services without compromising compliance.

The ability to concurrently bill for remote monitoring and other care management services reflects CMS’s commitment to providing comprehensive and coordinated healthcare. It encourages practitioners to leverage a combination of services to meet the diverse needs of patients.

Global Surgery Period in the Medicare Final Rule 2024

Billing practitioners cannot bill Medicare for RPM or RTM services during global surgery periods. However, practitioners not receiving global service payments, such as therapists, can provide these services during the global period, ensuring flexibility in patient care.

This distinction in billing practices during global surgery periods aims to balance the financial considerations for practitioners while focusing on patient care continuity. It encourages healthcare providers to adapt their billing strategies based on their specific patient treatment roles.

Separate Reimbursement: FQHCs and RHCs

Starting January 1, 2024, Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) can separately bill Medicare for RPM and RTM services, departing from the previous all-inclusive rate model. This change aims to enhance reimbursement and align with coding requirements.

The shift towards separate reimbursement for FQHCs and RHCs reflects a recognition of the unique challenges and services provided by these healthcare entities. It offers financial flexibility and acknowledges its role in delivering remote monitoring services to Medicare beneficiaries.

RPM Exclusion from MSSP Primary Care Services

While CMS considered including RPM CPT codes in the Medicare final rule 2024, the definition of primary care services for the Medicare Shared Savings Program (MSSP) ultimately chose not to. The concern lies in potential conflicts when specialists also bill RPM codes, affecting the assignment of primary care services under MSSP rules.

This decision reflects CMS’s commitment to maintaining the integrity of primary care services within the MSSP framework. By excluding RPM codes from the definition, CMS aims to prevent potential disruptions in assigning primary care services and ensure accurate representation in the program.

Understanding the Medicare Final Rule 2024

The Medicare final rule 2024 marks a milestone in the evolution of RPM and RTM Medicare billing. Despite increased clarity, some operational uncertainties persist, emphasizing the need for stakeholder engagement in future rulemaking to enhance the utilization of these services in advancing digital health models for patients.

We hope you have found these key takeaways helpful in further understanding the nuances within the Medicare Final Rule 2024. As healthcare providers navigate the evolving landscape of remote patient monitoring and therapeutic services, staying informed and actively participating in future rulemaking processes will be essential for optimizing patient care and compliance with CMS guidelines.

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