SWTRC NEWSLETTER - OCTOBER 2023

Bringing you up-to-date telehealth information resources on the Southwest region and the USA

Remote patient monitoring information, billing, and policy updates  

Remote patient monitoring (RPM) utilizes technology to inform clinical care decisions, enabling healthcare providers to monitor key metrics about their patients’ health conditions remotely. RPM devices typically include wireless network communications capabilities that enable the automatic transfer of health metrics data to an RPM clinical service provider (CSP). The RPM CSP monitors each patient’s data for trends or patterns that may indicate important changes in a patient’s health status and acts on this information to provide timely interventions to assist patients and their respective care teams to better manage each patient’s health conditions. RPM can be a great asset to people who have chronic health conditions, who are immunocompromised or immunosuppressed, or for whom travel is a barrier to accessing healthcare. 

Symptoms and conditions tracked through RPM include high blood pressure, diabetes, weight loss or gain, heart conditions, chronic obstructive pulmonary disease, sleep apnea, and asthma. RPM devices such as weight scales, pulse oximeters, blood glucose meters, and blood pressure monitors are generally easy to use and require only simple instructions. Patients need training to correctly utilize more complicated RPM devices which include apnea monitors, heart monitors, specialized monitors for dementia and Parkinson’s disease, breathing apparatuses, and fetal monitors.

RPM and other telehealth services have demonstrated a range of benefits for patients including improved health outcomes, reduced risk of contracting illnesses for both patients and healthcare workers, and prevented or shorter hospital stays for patients with a health status eligible for management via RPM. With its focus on preventative management of patients’ health conditions, RPM helps to reduce the incidence of monitored patients visiting emergency rooms. This is particularly beneficial for patients in medically underserved areas that lack nearby emergency room care facilities. 

The Center for Medicare and Medicaid Services (CMS) covers RPM services.  As of Spring 2023 thirty-four states have Medicaid agencies with documented reimbursement for RPM.  Private insurers must cover RPM according to any respective state requirements.  They may optionally provide coverage for RPM services that exceeds regulatory requirements and may have different requirements for non-mandated coverage.

Medicare’s RPM terminology, definition, and associated payment policies

Please note that Medicare uses a different term for RPM, “remote physiologic monitoring,” which is defined as non-face-to-face monitoring and analysis of physiologic factors used to understand a patient’s health status.

Medicare’s remote physiologic monitoring payment policies include:

• An established patient-physician relationship is required.
• Consent to receive remote physiologic monitoring services at the time services are furnished is allowed.
• Physicians and non-physician practitioners who are eligible to furnish evaluation and management services (E/M) may bill for remote physiologic monitoring services.

Medicare’s guidelines for remote physiologic monitoring services billed to CPT codes 99453 and 99454 include:

• Physiologic data must be electronically collected and automatically uploaded to the secure location where the data can be available for analysis and interpretation by the billing practitioner.
• The device used to collect and transmit the data must meet the definition of a medical device as defined by the FDA.
• Remote physiologic monitoring data must be collected for at least 16 days out of 30 days.
• Remote physiologic monitoring services must monitor an acute care or chronic condition.
• The services may be provided by auxiliary personnel under the general supervision of the billing practitioner.

Now that the COVID-19 public health emergency (PHE) has officially ended as of May 11, 2023, the CMS has updated its policies for remote physiologic monitoring. Per CMS, when the PHE ends, clinicians must once again have an established relationship with the patient prior to providing RPM services and clinicians must only bill for these services when at least 16 days of data have been collected. CMS will continue to allow RPM services to be furnished to patients with both acute and chronic conditions (pre-PHE, an initiating visit was required before RPM services could be billed). 

The proposed 2024 Medicare Physician Fee Schedule includes changes to Remote Patient Monitoring. 

Billing and reimbursement for RPM in Southwest Telehealth Resource Center region states

Providers can check their state’s policies at the Center for Connected Health Policy (CCHP) which is the federally designated National Telehealth Policy Resource Center.  A summary chart of state telehealth laws and reimbursement policies published by CCHP in Spring 2023, includes states’ Medicaid agencies’ RPM reimbursement status. 

Selected RPM information and resources by state:

AZ	Southwest Telehealth Resource Center’s Virtual Visit & Reimbursement Guide for Arizona Includes private insurers' RPM billing codes Arizona’s Medicaid agency, the Arizona Health Care Cost Containment System (AHCCCS) Defines RPM as personal health and medical data collection from a member in one location via electronic communication technologies, which is transmitted to a provider in a different location for use in providing improved chronic disease management, care, and related support. Such monitoring shall be either synchronous (real-time) or asynchronous (store and forward). AHCCCS covers service delivery via RPM and will reimburse for RPM in their fee-for-service program. Managed care organizations must abide by AHCCCS fee-for-service coverage policy.  AHCCCS billing code set available here. AHCCCS covers RPM necessary for medical, behavioral health and surgical services by practitioners employed by Indian Health Services and tribes. RPM is included in the State of Arizona’s definition of telehealth also defined here.
CO	Southwest Telehealth Resource Center’s Virtual Visit & Reimbursement Guide for Colorado Includes private insurers' RPM billing codes Telehealth monitoring is available in Colorado for members who are eligible through the Home Health benefit and should not be billed as telemedicine. The Colorado Medical Assistance Program will reimburse for home health care or home and community-based services through telemedicine at a flat fee set by the state board. Home care agencies and home care placement agencies rules must allow for supervision in person or by telemedicine or telehealth. Any rules adopted by the board shall be in conformity with applicable federal law and must take into consideration the appropriateness, suitability and necessity of the method of supervision permitted. The Home Health Agency shall create policies and procedures for the use and maintenance of the monitoring equipment and the process of telehealth monitoring. The Home Health Agency shall provide monitoring equipment that possesses the capability to measure any changes in the monitored diagnoses and meets all the safety requirements in the regulation. Home Health Telehealth services are covered for clients receiving Home Health Services for telehealth monitoring. Colorado Medicaid covers home health telehealth, which includes frequent and ongoing self-monitoring of members through equipment left in the member’s home which is designed to measure the common signs and symptoms of disease exacerbation before a crisis occurs allowing for timely intervention and symptom management.
NV	Southwest Telehealth Resource Center’s Virtual Visit & Reimbursement Guide for Nevada Includes private insurers' RPM billing codes No active state Medicaid agency reimbursement requirement for RPM.
NM	Southwest Telehealth Resource Center’s Virtual Visit & Reimbursement Guide for New Mexico Includes private insurers' RPM billing codes No active state Medicaid agency reimbursement requirement for RPM.