7/28/2023 0 Comments Reiterating to clarify meaning![]() Who can furnish RPM services and obtain consent? Despite requests to allow other providers to bill for RPM services, the 2021 Final Rule confirmed RPM can be ordered and billed only by physicians or non-physician practitioners who are eligible to bill Medicare for E/M services. RPM codes are considered Evaluation and Management (E/M) services. ![]() Nowadays, state laws allow doctors to use telehealth to create a valid doctor-patient relationship for new patients. Moreover, CMS generally defers to state laws on professional practice requirements, clinical standards of care, and valid doctor-patient relationships. And we do know that “new patient E/M service” codes (e.g., CPT Codes 99201-99205) are listed among the Medicare-covered telehealth services. However, we do know that, for Medicare telehealth services, CMS allows the use of real-time interactive audio-video technology to satisfy the face-to-face element of an E/M service. To date, CMS has not issued public guidance on physicians using telehealth to conduct a new patient E/M service prior to enrolling a beneficiary in an RPM program. Typically, this will require the practitioner to conduct a new patient E/M service. After the PHE waiver expires, there will need to be an established patient-practitioner relationship in order to bill Medicare for CPT 99453, 99454, 99457, and 99458. CMS’ waiver suggests (but does not explicitly state) that during the PHE, practitioners may render RPM services without first conducting a new patient E/M service. CMS waived the “established patient” restriction during the Public Health Emergency (PHE) but in the 2021 Final Rule, CMS declined to extend such waiver beyond the PHE. As a result, the physician would possess information needed to understand the current medical status and needs of the patient prior to ordering RPM services to collect and analyze the patient’s physiologic data and to develop a treatment plan. During that new patient E/M service, the physician would have collected relevant patient history and conducted a physical exam, as appropriate. In the 2021 Final Rule, CMS stated that RPM services are limited to “established patients.” In support of this position, CMS asserted that a physician who has an established relationship with a patient would likely have had an opportunity to provide a new patient E/M service. Can RPM be used with new and established patients, alike? In 2019, CMS initially described RPM as services rendered to patients with chronic conditions, but confirmed in the 2021 Final Rule that practitioners may furnish RPM services to remotely collect and analyze physiologic data from patients with acute conditions, as well as patients with chronic conditions. ![]() 2. Must the patient have a chronic condition to qualify for RPM? RPM involves the collection and analysis of patient physiologic data that are used to develop and manage a treatment plan related to a chronic and/or acute health illness or condition. The ten RPM Frequently Asked Questions below are based on CMS’ policies in the 2021 Final Rule. This rule finalizes many of the proposals released in August 2020, and builds upon previous RPM guidance , including changes allowing general supervision for purposes of incident to billing. The changes, part of the 2021 Physician Fee Schedule final rule are intended to clarify CMS’ position on how it interprets requirements for RPM services. ![]() On December 1, 2020, the Centers for Medicare and Medicaid Services (CMS) finalized new policies related to remote patient monitoring aka remote physiologic monitoring or “RPM,” reimbursed under the Medicare program.
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