Posts in Medicare
Remote Therapeutic Monitoring in the 2022 MPFS: How CMS Can (and Should) Get it Right
Remote Therapeutic Monitoring in the 2022 MPFS: How CMS Can (and Should) Get it Right

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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Digital Health, Healthcare Reform, Medicare, Physician Fee Schedule, Reimbursement, Remote Patient Monitoring, Regulations, Telehealth, TelemedicineCarrie Nixon2022 Medicare Physician Fee Schedule, Remote Therapeutic Monitoring, remote patient monitoring, Remote Monitoring, virtual care, RPM, RTM, MPFS, 2022, proposed rule, proposed medicare physician fee schedule, medicare physician fee schedule, CMS
New Remote Therapeutic Monitoring CPT codes introduced in Proposed 2022 Medicare Physician Fee Schedule
New Remote Therapeutic Monitoring CPT codes introduced in Proposed 2022 Medicare Physician Fee Schedule

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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Digital Health, Physician Fee Schedule, Medicare, Reimbursement, Remote Patient MonitoringCarrie Nixon and Kaitlyn O'Connorremote patient monitoring, RPM, Remote Therapeutic Monitoring, RTM, 2022 Medicare Physician Fee Schedule
Carrie Nixon in mHealth Intelligence Discussing the 2021 MPFS Reimbursements for RPM
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.

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CMS Programs, Digital Health, Healthcare Reform, Medicare, Physician Fee Schedule, Regulations, Remote Patient Monitoring, ReimbursementCarrie NixonRPM, remote patient monitoring, 2021 MPFS, 2021 Medicare Physician Fee Schedule
What is a Value-Based Enterprise? New Opportunities for Digital Health and Healthcare Innovation
What is a Value-Based Enterprise? New Opportunities for Digital Health and Healthcare Innovation

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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Digital Health, Fraud and Abuse, Medicare, OIG, Provider, Regulations, Remote Patient Monitoring, ReimbursementCarrie NixonDigital Health, fraud and abuse, AKS, AKS Safe Harbor, Anti-Kickback Statue, Stark Law, Stark, CMS, regulations, remote patient monitoring, OIG
Carrie Nixon in mHealth Intelligence Discussing the 2021 Medicare Physician Fee Schedule
Carrie Nixon in mHealth Intelligence Discussing the 2021 Medicare Physician Fee Schedule

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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CMS Programs, Digital Health, Healthcare Reform, Medicare, Physician Fee ScheduleCarrie Nixontelehealth, remote patient monitoring, 2021 MPFS, 2021 Medicare Physician Fee Schedule, rpm, RPM, Carrie Nixon
Op-ed by Carrie Nixon in The Hill: 5 Actions to Fuel the Digital Health Momentum
Op-ed by Carrie Nixon in The Hill: 5 Actions to Fuel the Digital Health Momentum

Nixon Law Group’s Managing Partner, Carrie Nixon, was quoted in an op-ed for The Hill discussing 5 actions to fuel the digital health momentum. "The COVID-19 public health emergency has forcefully opened the door for widespread adoption of telehealth, remote patient monitoring, and other digital health platforms by patients and providers alike."

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Digital Health, COVID-19, CMS Programs, Healthcare Reform, Legislation, Medicare, OIG, Press, Regulations, Remote Patient Monitoring, TelehealthCarrie NixonTelehealth, Telemedicine, Remote Patient Monitoring, COVID-19, Coronavirus, Digital Health, regulations, legislation, Carrie Nixon
How to make sure you get (and keep) your Medicare CARES Provider Relief Fund Payment
How to make sure you get (and keep) your Medicare CARES Provider Relief Fund Payment

Medical providers across the spectrum have endured a significant hit to revenues as a result of the COVID-19 public health emergency (PHE). MGMA’s recent report, “COVID-19 Financial Impoact on Medical Practices”, indicates that nearly 100% of providers have seen a negative revenue impact, with an average decrease in revenue of 55%. To offset some of those losses, the CARES Act allocated a $50 billion “general allocation” to support the sustainability of these providers.

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COVID-19, MedicareRebecca GwiltCoronavirus, COVID-19, Medicare, cares act
Telehealth, Virtual Visits, e-Visits, and Remote Care for Nursing Homes during the COVID-19 Public Health Emergency (PHE)
Telehealth, Virtual Visits, e-Visits, and Remote Care for Nursing Homes during the COVID-19 Public Health Emergency (PHE)

The burden on the staff and residents of long-term care facilities, including nursing facilities and skilled nursing facilities, has increased significantly around the country. The Centers for Medicare and Medicaid Services (CMS), in response to feedback from industry stakeholders, and under new 1135 waiver authorities granted to it in the Coronavirus Preparedness and Response Supplemental Appropriations Act, implemented several policy changes to support long term care facilities, including changes enabling practitioners to remotely provide services to these facilities and to remotely supervise on-site providers. 

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COVID-19, Assisted Living, CMS Programs, Digital Health, Healthcare Reform, Medicare, Regulations, Reimbursement, TelehealthRebecca GwiltCoronavirus, COVID-19, nursing home, Teleheath, virtual check-in, e-Visit, remote care
NEW! Medicare to Reimburse for Acupuncture Services
NEW! Medicare to Reimburse for Acupuncture Services

On January 21, 2020, the Centers for Medicare and Medicaid Services (CMS) finalized a decision (under National Coverage Determination (NCD) 30.3.3) to cover acupuncture for Medicare patients, specifically those with chronic low back pain (cLBP).

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CMS Programs, Healthcare Reform, Medicare, ReimbursementTommy MillerCMS, Reimbursement, Medicare, chronic condition, back pain, CPT code 97810, CPT code 97811, CPT code 97813, CPT code 97814
Principal Care Management (PCM) Reimbursement under the 2020 Medicare Physician Fee Schedule
Principal Care Management (PCM) Reimbursement under the 2020 Medicare Physician Fee Schedule

The 2020 Medicare Physician Fee Schedule (the “Final Rule”), released on November 1, 2019, finalized two new codes in a new category of reimbursement titled “Principal Care Management” (PCM) Services. The new codes will be effective as of January 1, 2020, and provide reimbursement for managing a patient’s care for a single high-risk disease or complex chronic condition.

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Healthcare Reform, Physician Fee Schedule, Medicare, Remote Patient MonitoringKaitlyn O'ConnorPrincipal Care Management, PCM, 2020 Medicare Physician Fee Schedule, MPFS, 2020 MPFS, CCM
Proposed Anti-Kickback Statute “Patient Engagement and Support” Safe Harbor: Implications for Remote Patient Monitoring and other Care Management Services Vendors
Proposed Anti-Kickback Statute “Patient Engagement and Support” Safe Harbor: Implications for Remote Patient Monitoring and other Care Management Services Vendors

In this article on the proposed changes to the fraud and abuse regulations, we focus on OIG’s proposed Patient Engagement and Support safe harbor to AKS and CMP and discuss how this new safe harbor may affect care management services vendors such as Chronic Care Management (CCM), Remote Patient Monitoring (RPM), Transitional Care Management (TCM), and Behavioral Health Integration (BHI) services vendors.

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Fraud and Abuse, Medicare, OIG, Regulations, Remote Patient MonitoringCarrie Nixon and Kaitlyn O'ConnorRPM, CCM, Care Management Services, Remote Patient Monitoring, AKS, AKS Safe Harbor, OIG, Patient Engagement, Chronic Care Management
How to Get Paid for Patient "e-Visits" under the 2020 Medicare Physician Fee Schedule
How to Get Paid for Patient "e-Visits" under the 2020 Medicare Physician Fee Schedule

The Centers for Medicare and Medicaid Services (CMS) released the Final Medicare Physician Fee Schedule for CY 2020 (the “2020 MPFS”) on November 1, 2019. The 2020 MPFS finalizes six new CPT codes for e-Visits, providing new opportunities for physician practices to be reimbursed for conducting digital health assessments and evaluations for their patients and for remote patient monitoring companies to add these capabilities to their platforms.

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CMS Programs, Healthcare Law Firm, Medical Practice, Medicare, Physician Fee Schedule, Physicians, Regulations, Remote Patient Monitoring, ReimbursementKaitlyn O'ConnorRemote Patient Monitoring, Remote Monitoring, RPM, Digital Health, virtual care, 2020 MPFS, 2020 Medicare Physician Fee Schedule, Coronavirus
CMS Finalizes Changes to Remote Patient Monitoring in the 2020 Medicare Physician Fee Schedule
CMS Finalizes Changes to Remote Patient Monitoring in the 2020 Medicare Physician Fee Schedule

The Centers for Medicare and Medicaid Services (CMS) released the Final Medicare Physician Fee Schedule for CY 2020 (the “2020 MPFS”) on November 1, 2019, finalizing some important changes relating to Remote Patient Monitoring (RPM) services, but leaving many questions unanswered as of yet.

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Medicare, Physician Fee Schedule, Reimbursement, Remote Patient MonitoringCarrie NixonMPFS, 2020 MPFS, Remote Patient Monitoring, 2020 Medicare Physician Fee Schedule, Interprofessional Internet Consultations, Communication Technology Based Services, Reimbursement, Coronavirus
The “Lower Drug Costs Now Act”: See Change Possible for State and Federal Drug Transparency and Pricing
The “Lower Drug Costs Now Act”: See Change Possible for State and Federal Drug Transparency and Pricing

Despite division along party lines and industry pushback, the House of Representatives has passed legislation (H.R. 3), the “Lower Drug Costs Now Act”, which would require the Department of Health and Human Services (DHHS) to establish a “Fair Price Negotiation Program” responsible for negotiating Medicare payments for some of the most expensive drugs available to Medicare beneficiaries.

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FDA, Healthcare Reform, Legislation, Medicare, RegulationsTommy MillerLife Sciences and Biotech, drug and alcohol, drug pricing
Proposed 2020 Medicare Physician Fee Schedule offers new reimbursement for Remote Patient Monitoring
Proposed 2020 Medicare Physician Fee Schedule offers new reimbursement for Remote Patient Monitoring

On July 29, 2019, the Center for Medicare and Medicaid Services (“CMS”) released its proposed rule for the 2020 Medicare Physician Fee Schedule (the “2020 MPFS”).

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Health IT, Medical Practice, Physician Fee Schedule, Medicare, Physicians, Remote Patient MonitoringCarrie NixonRemote Monitoring, Remote Patient Monitoring, Medicare, 2020 Medicare Physician Fee Schedule, physician practice, Physicians, Reimbursement, Coronavirus
Nixon Law Group joins the ACO Exhibit Hall
Nixon Law Group joins the ACO Exhibit Hall

Nixon Law Group is pleased to be the only legal services provider in the ACO Exhibit Hall! This virtual exhibit hall was created to serve physicians and provider entities participating in (or desiring to participate in) Accountable Care Organizations, including the Medicare Shared Savings Program models, NextGen ACOs, commercial shared savings arrangements, and other value-based reimbursement models.

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Medicare, Physicians, Vendor RelationsCarrie NixonACO, Medicare ACO, Medicare Shared Savings Program
New CMS Innovation Models: Primary Care First and Direct Contracting
New CMS Innovation Models: Primary Care First and Direct Contracting

In April, the U.S. Department of Health and Human Services (HHS) and the Centers for Medicare and Medicaid Services (CMS) announced a new set of payment models meant to allow primary care providers deliver better care at a lower cost to their patients by removing unneccessary administrative and adjust payouts from procedures to outcomes.

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CMS Programs, Healthcare Reform, Medicare, Physicians, Medical Practice, Regulations, ReimbursementCarrie NixonHealthcare innovation, CMS, Medicare, medicaid, regulations