On July 27, 2018 CMS published proposed rule which affected RPM codes for HHS and on Nov 1, 2018 published the Final rules and interim final rules.
This article provides an understanding of rules related to CPT codes for RPM which seemed to have changed between the two rulings. We start with some important takeaways for Remote Patient Monitoring for Home Health Agencies for 2019 CMS rulings along with a side by side table providing relevant details of the CPT codes
- CMS shows commitment to RPM in PDGM Final Rule – CMS acknowledged the benefit of the use of remote patient monitoring (RPM) to augment the home health plan of care. CMS believes remote patient monitoring could enable the HHA to more quickly identify any changes in the patient’s clinical condition, prompting faster action by clinical staff or physician to review potential changes to the patient’s care plan. Remote patient monitoring (RPM) could augment home health visits for example in the home health scenario where patient is admitted for observation and assessment of the patient’s condition due to a possible potential for complications or possible potential for an acute episode.
CMS believes that remote patient monitoring improves patients’ ability to maintain independence, improving their quality of life, which is especially true for patients with Chronic Obstructive Pulmonary Disease (COPD) and Congestive Heart Failure (CHF). Research indicates that remote patient monitoring (RPM) has been successful in reducing readmissions and long-term acute care utilization.
- Two sets of RPM CPT Codes in two rulings -July 27, 2018 (page 236) proposed rule and Nov 2, 2018 (page 450) final and interim final rules. Difference CPT Codes were provided in the two rulings for RPM CPT Codes 990X0, 990X1 and 994X9 in the proposed rule and CPT codes 99453, 99454, 99457 in the final and interim final rules.
- RPM is not telehealth – Because these RPM codes describe services that are inherently non face-to-face, CMS does not consider them Medicare telehealth services under section 1834(m) of the Act; therefore, CMS did not add them to the list of Medicare telehealth services. This enables these services to be provided from home a boon for Home Health Agencies.
- RPM and CCM can be billed together – These RPM services may be billed for the same patient in the same month as Chronic Care Management (CCM) services, provided the time spent for CPT® 99457 is in addition to and not the same as the time spent for CCM services CPT® 99490, 99487, or 99489.
Here are RPM CPT Codes added starting CY 2019 (in proposed rule and final rules and interim final rule):
|CPT® July 27, 18||CPT® Nov 1, 18||Description||Frequency of Payment||Payment (Approx)|
|990X0||99453||RPM – initial; set-up and patient education on use of equipment. This reimbursement is for the initial work associated with onboarding a new patient, setting up the equipment, and patient education on use of the equipment.||One time||$21|
|990X1||99454||RPM initial; device(s) supply with daily recording(s) or programmed alert(s) transmission||30 days||$69/month|
|994X9||99457||RPM min 20 Minutes of qualified healthcare professional requiring interactive communication with the patient/caregiver||Calendar Month||$54/month|
Some terms used in this blog:
- CCM – Chronic Care Management
- CMS – Centers for Medicare & Medicaid Services
- RPM – Remote Patient Monitoring, Remote Physiologic Monitoring
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