The Centers for Medicare and Medicaid Services (CMS) recently announced its 2019 Medicare Physician Fee Schedule and Quality Payment Program, with some changes created to boost the use of patient engagement and remote patient monitoring (RPM).
CMS explains these amendments:
“Under this proposal, Medicare will start paying for virtual check-ins, meaning patients can connect with their doctor by phone or video chat,” said Seema Verma, CMS Administrator. “Many times this type of check-in will resolve patient concerns in a convenient manner that gets them the care that they need and avoids unnecessary cost to the system. This is a big issue for our elderly and disabled populations where transportation can be a burden to care as well as to caregivers. We’re not intending to replace office visits but rather to augment them and provide new access points for patients.”
Digital health expert Nathaniel Lacktman breaks down some of the biggest changes CMS proposes to boost support for services like patient management and store-and-forward telehealth:
1. Less treatment time required to qualify for reimbursement. CPT 99091 requires at least 30 minutes per 30-day period, whereas CPT 994X9 requires only 20 minutes per calendar month. The new code is much easier to track on a monthly basis, and requires 33 percent less time.
2. Separate payment for initial set-up and patient education. CPT 99091 does not offer additional reimbursement for the time spent setting up the RPM equipment or educating the patient on its use. The new codes offer separate reimbursement for the work associated with onboarding a new patient, setting up the RPM equipment and training the patient on same. This is a very helpful move to further incentivize providers to start using these technologies with their patients. In addition, this separate payment is different from how Medicare reimburses Durable Medical Equipment (DME) suppliers (e.g., CPAP, oxygen, etc.). CMS requires the DME supplier to set up the equipment at the patient’s home and educate the patient on how to use the equipment, but does not offer separate payment for that work.
3. Clinical staff allowed. CPT 99091 is limited only to “physicians and qualified health care professionals” and does not expressly allow the RPM service to be delivered by clinical staff (e.g., RNs, medical assistants, etc.). This means the physician or qualified health care professional must perform the full 30 minutes per 30-day period, which is a lot of time for these highly trained professionals. For some providers, this is too resource-intensive to justify the $58.68 per month reimbursement rate. The new code allows RPM services to be performed by clinical staff.
Providers will also be able to request reimbursement for the time and effort required to educate patients on the use of these new patient engagement and remote monitoring technologies, an immediate benefit to Rhinogram users, once the code is approved. By including new payment codes for these changes, the proposed rule exemplified CMS’ belief to bring the Medicare program into the future of clinically-valid telemedicine services.
Here at Rhinogram, we will continue building a product that will meet the future needs of healthcare providers and their patients. To learn more about the proposed CMS 2019 Physician Fee Schedule and Quality Payment program click here.