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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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If you are a medical professional interested in leveraging remote technology to optimize patient health, this guide outlines remote therapeutic monitoring codes for 2024 and how to bill using RTM CPT codes. Remote therapeutic monitoring (RTM) is similar to remote patient monitoring. However, RTM is used to acquire non-physiological patient data for the respiratory and musculoskeletal systems.

This data can monitor medication and exercise adherence, functional status, response to therapy, and musculoskeletal and respiratory activity. Patients use RTM devices to collect health data for musculoskeletal and respiratory system status, therapy, and medication response and adherence. Unlike in remote patient monitoring CPT Codes, the RTM patient data is self-reported and communicated to their physician. 

Remote Therapeutic Monitoring Codes

Healthcare providers can improve patient outcomes while establishing additional revenue streams with an established and efficient remote therapeutic monitoring service model. However, it is essential to note that regulations exist regarding which remote therapeutic monitoring codes can be billed together with remote patient monitoring. Providers are not allowed to double bill for RTM and RPM.

In 2022, The Center for Medicaid and Medicare (CMS) established remote therapeutic monitoring codes to help make billing for physical, occupational, and speech-language pathologists more accessible. Before 2022, these qualified healthcare professionals were not reimbursed for collecting data and educating patients using remote health devices. These new RTM CPT codes allow healthcare systems to increase revenue while improving patient outcomes and recovery programs.

RTM CPT codes are general management codes that qualified healthcare professionals, like physical and occupational therapists, can use to bill for their services, unlike RPM codes. The most commonly used RTM devices are a scale and spirometer. The 2024 RTM CPT codes, descriptions, payment rates, and billing frequency are listed below. 

2024 Remote Therapeutic Monitoring Codes

In this section, you will find a quick overview of remote therapeutic monitoring codes for 2024. All remote therapeutic monitoring services can be provided under general supervision. Physical therapists (PTs), occupational therapists (OTs), and speech-language pathologists (SLPs) can provide RTM services. RTM CPT codes can be used for “sometimes therapy,” allowing physicians, nurse practitioners, physician assistants, and clinical nurse specialists to perform RTM. 

CPT Code 98975

This code covers initial setup and patient education on the use of equipment. It can be billed once by one practitioner only when at least 16 days of data have been collected on at least one medical device. The average national payment rate for CPT 98975 is $19.65.

Respiratory CPT Code 98976

Billing CPT code 98976 pays for respiratory devices supplied with daily scheduled recordings and programmed alerts and transmission for monitoring the respiratory system. The code can be used every 30 days by one practitioner only when at least 16 days of data have been collected on at least one medical device. The average national payment rate for CPT code 98976 is $46.83.

Musculoskeletal CPT Code 98977

Code 98977 reimburses musculoskeletal devices supplied with daily scheduled recordings and programmed alerts and transmission for monitoring the musculoskeletal system. This can be billed once every 30 days by one practitioner only when at least 16 days of data have been collected on at least one medical device. The average national payment rate for CPT code 98977 is $55.72.

CPT Code 98980

RTM CPT code 98980 bills for the initial 20 minutes of treatment time per calendar month. Time must include at least one interactive communication via phone or video with the patient during the month. New in 2023, CPT 98980 can be billed “incident to” or under general supervision. CPT 99457 is billed every 30 days. The average national payment rate for CPT 98980 is $49.78.

CPT Code 98981

In 2024, CPT 98981 covers each additional 20 minutes of treatment time per calendar month. It requires at least one interactive communication during the calendar month. This code has the exact requirements as CPT 98980.  The average national payment rate for CPT 98981 is $39.30.

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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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Hospitals across the nation are facing financial constraints and unprecedented staffing shortages. This situation is compounded by the growing need to provide skilled, resource-intensive care for sicker patients being admitted to hospitals’ general care units.

This situation is not only impacting clinical staff, who are overworked, stretched thin and reporting high levels of burnout, but patients, who are more likely to experience a harmful safety event due to inadequate working conditions.

“The intersection of fewer providers and sicker patients is challenging hospitals a great deal,” said Dr. Sam Ajizian, Chief Medical Officer of the Patient Monitoring Operating Unit at Medtronic.

A powerful, impactful strategy to address this challenging landscape is for hospital leaders to leverage technology, specifically remote monitoring, connectivity, and interoperability solutions.

The impact of remote monitoring

Technology — particularly, remote patient monitoring — provides clinical staff with a significant gift: more time with patients.

Right now, clinicians spend far too much of their shift on administrative tasks such as manual charting. They continuously check routine vital signs and manually input the information into the electronic medical record, leading to short, stressful and unsatisfactory interactions with patients.

Remote patient monitoring automates some of this work for caregivers by enabling the continuous capture of vital patient data, which is then uploaded to the EMR and put in the hands of caregivers in the most convenient format for them, such as on a desktop, mobile app or tablet.

As a result, remote patient monitoring can help reduce burnout for clinicians as it decreases the need for manual charting and supports more one-on-one time with patients.

“Remote patient monitoring frees up a lot of nursing hours^3,5 where they can do what they went into the profession for — to talk to patients and give care. No provider went into healthcare to type on a computer,” Ajizian said.

The continuous capture of real-time patient data also allows clinicians to identify adverse patient trends earlier and intervene sooner, helping them improve patient outcomes overall.

In order to gather this data from patients continuously, the monitoring device, such as a wearable, must be comfortable for patients to wear. The BioButton multi-parameter wearable from BioIntellisense, part of Medtronic’s HealthCast portfolio, is small, with a self-adhesive, worn on the patient’s upper left chest, with up to 16 days of battery life. “The BioButton device offers an effortless user experience. Just stick it on and forget it” Ajizian said.   

The important role of connectivity

While the device used to continuously capture patient vital sign information is key to the success of remote patient monitoring programs, so is connectivity. Clinicians must be able to access patient data anytime, anywhere, quickly and easily.

“You can have the best wearable in the world but if the data can’t be displayed where the caregiver wants it and how they want to see it, it’s useless,” Ajizian said.

To achieve this, remote patient monitoring systems should be part of the existing ecosystem of devices and workflows, including the hospital’s EMR.

The HealthCast^TM Vital Sync^TM remote patient monitoring system allows clinicians to remain connected to their patients wherever they are in the hospital. The system is designed to connect to hospitals’ EMRs and existing devices. Additionally, it provides clinicians with actionable insights through near real-time trend and alert data on patients wherever they prefer to see it including via desktop or mobile app.   

The future of remote monitoring

Choosing a remote monitoring platform is a significant financial investment. In addition to considering the product features, hospitals should also factor in the quality of the partnership with the provider.

Hospitals must prioritize finding a partner that will offer long-term clinical, technical, education and maintenance support that puts patients and clinicians first. Medtronic understands the importance of partnering with hospitals to build sustainable remote monitoring programs.

“We meet the customer where they are, we fill in the gaps with the tech and we connect it in the easiest way possible,” Ajizian said.

Learn more about Medtronic’s HealthCast^TM intelligent patient monitoring, a portfolio of remote monitoring, connectivity and interoperable solutions, here.

Footnotes

1. Baker MA, Sands KE, Huang SS, et al. The Impact of Coronavirus Disease 2019 (COVID-19) on Healthcare-Associated Infections. Clin Infect Dis. 2022;74(10):1748-1754.
2. https://www.jointcommission.org/-/media/tjc/documents/resources/patient-safety-topics/sentinel-event/sentinel-event-general-information-and-2021-update.pdf
3. Bellomo R, Ackerman M, Bailey M, et al. A controlled trial of electronic automated advisory vital signs monitoring in general hospital wards. Crit Care Med. Aug 2012;40(8):2349-61.
4. Stellpflug C, Pierson L, Roloff D, et al. Continuous physiological monitoring improves patient outcomes. Am J Nurs. 2021;121(4):40–46.
5. Han WH, Sohn DK, Hwangbo Y, et al. Effect of a Wireless Vital Sign Monitoring System on the Rapid Response System in the General Ward. J Med Syst. 2022;46(10):64. Published 2022 Aug 26.
6. Downey C, Randell R, Brown J, Jayne DG. Continuous versus intermittent vital signs monitoring using a wearable, wireless patch in patients admitted to surgical wards: pilot cluster randomized controlled trial. J Med Internet. Res. 2018;20(12):e10802
7. Eddahchouri Y, Peelen RV, Koeneman M, Touw HRW, van Goor H, BrediS JH. Effect of continuous wireless vital sign monitoring on unplanned ICU admissions and rapid response team calls: a before-and-after study. Br JAnaesth. May 2022;128(5):857-863.
8. Verrillo SC, Cvach M, Hudson KW, Winters BD. Using Continuous Vital Sign Monitoring to Detect Early Deterioration in Adult Postoperative Inpatients.J Nurs Care Qual. Apr/Jun 2019;34(2):107-113.
9. Weller RS, Foard KL, Harwood TN. Evaluation of a wireless, portable, wearable multi-parameter vital signs monitor in hospitalized neurological and neurosurgical patients. J Clin Monit Comput. Oct 2018;32(5):945-951.

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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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