New CPT Codes provide additional reimbursement opportunities for remote monitoring of patient health data
The final 2019 Medicare Physician Fee Schedule (the “Rule”), released on November 1st, creates three new codes in the category of Chronic Care Remote Physiologic Monitoring (“CCRPM”) for (1) initial set-up and patient education, (2) initial device supply, and (3) monitoring data and interacting with patients or caregivers.
What are the new Chronic Care Remote Patient Monitoring Codes?
The final code descriptors for the new CCRPM codes read as follows:
CPT Code 99453: Remote monitoring of physiologic parameter(s) (eg, weight, blood pressure, pulse oximetry, respiratory flow rate), initial; set-up and patient education on use of equipment
CPT Code 99454: Remote monitoring of physiologic parameter(s) (eg, weight, blood pressure, pulse oximetry, respiratory flow rate), initial; device(s) supply with daily recording(s) or programmed alert(s) transmission, each 30 days
CPT Code 99457: Remote physiologic monitoring treatment management services, 20 minutes or more of clinical staff/physician/other qualified healthcare professional time in a calendar month requiring interactive communication with the patient/caregiver during the month
What you need to know about CPT Codes 99453, 99454, and 99457
CMS stated in the Rule that it plans to issue further guidance to help practitioners and stakeholders determine the scope of service and better interpret the code descriptors listed above. Specifically, we can expect guidance on (i) the types of technology that can be used to provide these new RPM services, (ii) whether the descriptor for CPT Code 99454 includes transmissions that occur other than daily, and (iii) whether CPT Code 99453 can be furnished via telecommunication technology.
Until then, we can answer the following questions:
1. Who can bill CPT Code 99457?
CPT Code 99457 allows for reimbursement for time spent by the billing physician, a qualified healthcare professional (“QHCP”), or clinical staff. All practitioners must practice in accordance with applicable state law and scope of practice laws.
2. How much time is required to bill CPT Code 99457?
The code requires the physician, QHCP, or clinical staff to spend at least 20 minutes per calendar month providing CCRPM services to a particular patient in order to receive reimbursement.
3. Can CPT Code 99457 be billed “Incident To”?
The Rule states that CPT Code 99457 describes only professional time and “therefore cannot be furnished by auxiliary personnel incident to a practitioner’s professional services.” This position is in stark contrast to CMS’s current stance on traditional Chronic Care Management (CCM) services, whereby CMS has not only allowed the services to be billed “incident to,” but has also allowed the incident to services to be performed under general supervision rather than the more strict direct supervision as is typically required for incident to billing. This position also appears to contradict the descriptor of the code itself, which states the services can be furnished by clinical staff. It is unclear why CMS has taken this new position, but for now, practitioners should refrain from billing CPT Code 99457 when furnished incident to their professional services.
4. How is CPT Code 99457 different from CPT Code 99091?
CPT Code 99457 differs from CPT Code 99091 in a few ways:
For more detailed information regarding CPT Code 99091, check out our post from earlier this year.
5. Can I receive reimbursement for supplying the device and educating the patient?
Yes. CPT Code 99453 provides reimbursement for initial set-up and patient education on how to use the monitoring equipment, and CPT Code 99454 provides reimbursement for supplying the device. Note that 99454 can be billed each 30 days.
Understanding the details of these requirements is critical to implementing a successful and compliant remote patient monitoring program. For assistance, please contact Nixon Law Group.
Interested in learning more about the 2019 Medicare Physician Fee Schedule? Check out our other posts by clicking the links below: