Posts in Reimbursement
Under 2022 Medicare Physician Fee Schedule, Physician Assistants Will Be Paid Directly for Services

On November 2, 2021, the Centers for Medicare and Medicaid Services (“CMS”) released its Final Medicare Physician Fee Schedule for 2022 (the “Final 2022 MPFS”), revising certain payment policies for services provided to Medicare beneficiaries by healthcare practitioners. These policies take effect on January 1, 2022.

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New Reimbursement for Remote Therapeutic Monitoring in the Final 2022 Medicare Physician Fee Schedule

This article examines the new CPT codes for Remote Therapeutic Monitoring as finalized for reimbursement in the 2022 Medicare Physician Fee Schedule, discussing key takeaways and implications for digital health and remote patient monitoring companies.

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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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Proposed 2022 MPFS: Expansion in Audio-Only Telehealth, Permanent Remote “Direct Supervision”, and Remaining Opportunities for New Permanent Telehealth Codes

CMS didn’t propose to add any permanent telehealth codes, but did incrementally expand patient access to telehealth in other ways.

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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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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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Webinar Recording: Remote Patient Monitoring and Virtual Care: Trends, Changes and Clarifications under the 2021 MPFS

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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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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2021 Trends and Opportunities for Healthcare Providers, Digital Health, and Life Sciences Innovators

2020 was the year that showed us all that you can’t truly predict what lays ahead. But, for all the surprises of the last year, the industry didn’t collapse, it accelerated along familiar trend lines. So, after a year like 2020, should we even attempt to predict what will happen in 2021? We say yes. And here’s why…

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Remote Patient Monitoring in the 2021 Medicare Physician Fee Schedule: The good, the bad, and the ugly

On December 1, 2020, the Centers for Medicare and Medicaid Services (“CMS”) released its Final Medicare Physician Fee Schedule for 2021 (the “Final 2021 MPFS”), revising payment policies for services provided to Medicare beneficiaries by medical practitioners. These policies will take effect on January 1, 2021. Read on for insights from Team NGL.

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Reimbursement for Virtual Check-ins and e-Visits in the Proposed 2021 Medicare Physician Fee Schedule

On August 3, 2020, the Centers for Medicare & Medicaid Services (“CMS”) released it Proposed Medicare Physician Fee Schedule for CY 2021 (“Proposed MPFS”), seeking to expand reimbursement for Virtual Check-ins and e-Visits as a way of improving access to patient care. CMS proposes seven new HCPCS codes for these “Communication Technology-Based Services” that could be billed by practitioners who cannot bill Evaluation and Management (“E/M”) services independently.

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Remote Patient Monitoring in the 2021 Proposed Medicare Physician Fee Schedule

Last evening, the Centers for Medicare & Medicaid Services (“CMS”) issued its proposed Medicare Physician Fee Schedule for CY 2021 (the “MPFS”). In addition to a number of important changes relating to the provision and reimbursement of telehealth, the proposed MPFS includes long-awaited clarifications around use of the Remote Patient Monitoring (“RPM”) codes established over the past three years

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Rebecca Gwilt on the Legal Case for Home Health Telehealth Reimbursement in Home Health Care News

Nixon Law Group’s Partner, Rebecca Gwilt, was quoted extensively in an article appearing in Home Health Care News regarding her views on the legal case for home health telehealth reimbursement.

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CMS clarifies use of Remote Patient Monitoring during COVID-19 and further expands Telehealth for Physical Therapists, Occupational Therapists, Speech Pathologists, other practitioners

The Center for Medicare and Medicaid Services (“CMS”) has issued a second Interim Final Rule (“IFR2”) that includes additional expansions and clarifications relating to the provision and reimbursement of telehealth, remote patient monitoring, and telephone services during the COVID-19 Public Health Emergency (“PHE”). While these expansions are another step forward for the adoption of digital technologies and services in healthcare, there are additional changes needed in the near-term, as detailed in the summary below.

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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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Webinar and Discussion: Reimbursement and Implementation of Telehealth, Remote Patient Monitoring, and Virtual Check-Ins during COVID-19...and Beyond

Join us for a webinar to explain the most recent regulatory and reimbursement changes around the Remote Patient Monitoring, Telehealth, e-Visit, and Virtual Check-in CPT codes, during COVID-19, and what those changes mean from a practical perspective.

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CMS issues Interim Rule on use of Telehealth, Remote Patient Monitoring, e-visits, and Virtual Check-Ins during COVID-19

In response to urgent requests from healthcare providers and digital health services companies, CMS released an Interim Final Rule with comment period (the “Rule”) on March 30, 2020 that eases restrictions around the use of telehealth and other virtual communications technologies to aide response to the COVID-19 public health crisis. The Rule adds reimbursement for over 80 additional services that can now be furnished by telehealth, removes the requirement that Medicare patients have a previously established relationship with the provider billing for telehealth or remote communications services, and allows the “face-to-face” encounters required to initiate some services to be conducted via telehealth.

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