This is our take on the approach CMS should follow in improving and finalizing the RTM codes and associated reimbursement that improve patient outcomes and lower the overall cost of care. It is based on our extensive work with remote patient monitoring and care management digital health companies along with the physician practices who use the existing care management codes – including Remote Patient Monitoring (“RPM”), Chronic Care Management, Principal Care Management, and Behavioral Health Integration.
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On July 13th, the Centers for Medicare and Medicaid Services (“CMS”) released its proposed Medicare Physician Fee Schedule for Calendar Year 2022 (the “2022 Proposed MPFS” or the “Proposed Rule”). In doing so, it recognized five new CPT codes for Remote Therapeutic Monitoring (“RTM”) of “non-physiologic” patient data such as “musculoskeletal system status, respiratory system status, therapy (medication) adherence, and therapy (medication) response” as well as pain. While this new code set is welcomed by advocates for virtual care, the 2022 Proposed MPFS that discusses RTM may raise just as many questions as it answers.
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We’ve hit the record button during our weekly Partner meeting to talk about the increased scrutiny of telemedicine and virtual care service by the Office of the Inspector General (OIG), as reflected in the latest OIG work Plan and ongoing audits and evaluations.
This conversation is especially relevant for those of you in the telehealth/digital health space, whether you’re a healthcare provider or platform/tech providers.
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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.
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Join Nixon Gwilt Law’s Carrie Nixon and Kaitlyn O’Connor for a presentation and discussion about Remote Patient Monitoring and other virtual care services, with a particular focus on how these services are addressed in the 2021 Medicare Physician Fee Schedule and what that may mean for business and reimbursement models going forward.
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Dramatic changes to the Anti-Kickback Statute and the Stark Physician Self-Referral Law regulations present an unprecedented opportunity for healthcare providers and digital health companies to create new business arrangements that align incentives around care coordination and patient engagement. Such arrangements are the foundation of the Value-Based Enterprise.
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Nixon Gwilt Law’s Managing Partner, Carrie Nixon, was quoted in an article appearing in mHealth Intelligence discussing the recent changes to Telehealth and Remote Patient Monitoring with the new 2021 Medicare Physician Fee Schedule (learn about our take here and here).
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