2024 CMS Payment Policies Further Increase Access to RPM Services
Blog:
There is no question that telehealth is now an integral part of the healthcare delivery ecosystem. While most Americans associate the term primarily with virtual visits, health tech innovators are creating buzz combining technology and telehealth to improve access to care (particularly in the arena of chronic care management) and better health outcomes through Remote Patient Monitoring (RPM) services. RPM services allow patients with chronic and often comorbid conditions to track health metrics from the convenience of their homes, or on-the-go, with wearable devices that automatically deliver health data to their healthcare providers who can monitor these conditions in real-time. RPM is the touted cure to missed appointments and, as a result, poorer health outcomes for patients with chronic conditions.
Expansion in access to RPM services has boomed since 2019, driven by payment policies issued by the Centers for Medicare and Medicaid Services (CMS) allowing providers to bill for RPM services, and further aided by the COVID-19 public health emergency (PHE). From payors’ perspectives, RPM services reduce the overall cost of patient care – particularly for patients with chronic health conditions - and are viewed as a bridge for promoting value-based care models.[1] The expansion in payment opportunities by CMS (and later to follow, state Medicaid programs and commercial payors), has created a ripe market for health tech entrepreneurs looking to play in the RPM space. The Remote Patient Monitoring (RPM) Market had a worth of USD 51.4 billion in 2022 and is projected to attain USD 354.49 billion by 2030.[2]
On November 2, CMS released the final Medicare Physician Fee Schedule for 2024 (the “Final Rule”) ushering in a number of welcome payment policy changes to increase access to RPM services, specifically related Remote Physiologic Monitoring (RPM) and Remote Therapeutic Monitoring (RTM). Highlights of the Final Rule include:
Allowing federally qualified health centers (FQHCs) and rural health clinics (RHCs) to receive reimbursement for RPM and RTM services outside of the FQHC per visit payments RHC all-inclusive rates. The Final Rule allows FQHCs and RHCs to bill HCPC code G0511 (general care management) for RPM and RTM services multiple times per month for the same patient as long as all requirements are met. In previous years, G0511 could only be billed once per month per patient, and RPM or RTM services were not covered. Despite this expansion, the reimbursement amount for this code will be reduced in 2024 from $77.94 to $72.98.
The direct supervision requirement for therapy assistants in private physical or occupational therapy practices is being relaxed. Starting in 2024, only general supervision will be required for therapy assistants furnishing RTM services.
The Final Rule pulled back on flexibility extended during the COVID-19 public health emergency (PHE), noting that with the end of the PHE, CMS’ payment policy will revert and RPM services will only be allowed to be furnished to established patients, meaning that chronic care patients must have at least one in-person visit with their provider before utilizing RPM.
The Final Rule also reverted to the pre-PHE requirement that RPM and RTM codes requiring data collection minimums must reflect 16 days of data collected in a 30-day period in order to be paid. Patients can be billed only once for these services every 30 days. However, the Final Rule allows providers to bill for either RPM or RTM services along with other care management services in the same period, marking a change from previous years, when neither of these services could be billed concurrently with other care management services.
As CMS and other healthcare payors continue to push health care providers towards outcomes-based payments, we can anticipate continued growth in the RPM services market. With the most recent Final Rules changes, state Medicaid plans are likely the next payors to follow suit in making payment policy changes to provide for greater access to RPM services.
For more information on CMS policies related to billing for RPM services, contact Jennifer P. Whitton or Laurice Rutledge Lambert.
[1] Rimi, a leader in the RPM services space, discusses the intersection of RPM services and value-based care here.
[2] See, SNS Insider, Remote Patient Monitoring (RPM) Market Size is to Hit USD 354.49 Bn by 2030 Driven by Increasing Prevalence of Chronic Diseases and the Growing Elderly Population (May 8, 2023), available here.