Carrie Nixon in mHealth Intelligence Discussing the 2021 MPFS Reimbursements for RPM
Nixon Gwilt Law’s Managing Partner, Carrie Nixon, was quoted in an article appearing in mHealth Intelligence discussing the January amendments by the Centers for Medicare & Medicaid Services to the 2021 Physician Fee Schedule to clarify reimbursement for remote patient monitoring programs.
When the final rule was issued in December, Carrie Nixon, co-founder and managing partner of the Nixon Gwilt law firm, took exception to the requirement that 16 days of data be collected over a 30-day period.
“Numerous stakeholders responded with clinical examples of such conditions that could readily be managed with fewer data transmissions, and even some instances in which requiring 16 separate transmission can be damaging to patients – for example, transmission of a patient’s weight in managing obesity,” she said. “Despite these specific examples, CMS stated in the Final 2021 MPFS that 'although we received general support for a reduction in the number of days of data collection required to bill for CPT codes 99453 and 99454, we did not receive specific clinical examples … we are not extending the interim policy to permit billing for CPT codes 99453 and 99454 for fewer than 16 days in a 30-day period.' Notably, the Final 2021 MPFS does not appear to prohibit billing CPT codes 99457 and 99458 when 20 minutes of care management services time has accrued during a calendar month, regardless of whether or not 16 days of transmissions have occurred during that time.”