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CMS Updates RPM Billing Codes

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In its December 2020 update to the 2021 Physician Fee Schedule (PFS), the Centers for Medicare and Medicaid Services (CMS) finalized payment rules for remote physiologic monitoring (RPM) described by five CPT codes 99453, 99454, 99091, 99457, and 99458. Two changes to RPM services were also finalized in response to the COVID-19 Public Health Emergency (PHE). Pack4U helps physicians to care for their patients by introducing connected technology into the home, providing remote monitoring and triaging to primary care as needed.

What’s Covered

  • RPM services may be medically necessary for patients with acute conditions as well as patients with chronic conditions.

Who Can Bill

  • Qualified health care providers (QHCPs) or non-physician practitioners (NPPs) may provide services described by CPT codes 99453 and 99454 as part of the physician’s services and under their supervision.
  • Additionally, under CPT codes 99453 and 99454, CMS permanently established that auxiliary personnel (including clinical staff and contracted employees) may provide RPM patient education and device setup.
  • Pack4U QHCPs provide education, device setup and monitoring on behalf of physicians.

Consent Timing

  • The new rule allows consent for RPM services at the time that RPM services are provided versus in advance and in person.

Approved Devices

  • The medical device supplied to a patient as part of RPM services must meet FDA requirements; be reliable and valid, and the data must be automatically collected and transmitted electronically.
  • Pack4U provides spencer, an FDA-approved class 1 medical device, which we use to monitor medication adherence, ask questions for patient reported outcomes, link readings from blue tooth enabled devices to medication administration, and use telehealth capabilities with an embedded camera.

Types of Communication & Services

  • For CPT codes 99457 and 99458, an “interactive communication” is defined as a two-way conversation that occurs in real-time that can be enhanced with video or other kinds of data as described by HCPCS code G2012.
  • The 20-minutes required to bill for the services of CPT codes 99457 and 99458 can include time for providing care management services and for the required interactive communication.
  • Pack4U telepharmacy services are provided in collaboration with Tabula Rasa Healthcare and CHC Health.

Post COVID-19

  • Following the end of the COVID-19 PHE, for RPM services to be provided there must be an established patient-physician relationship.
  • To meet the requirements to bill CPT codes 99453 and 99454, 16 days of data each 30 day period must be collected and transmitted vs. 2 days of data during the PHE.
  • Pack4U ensures data thresholds are met and provides physician practices with monthly reports to simplify their RPM billing.

These changes reflect a broader CMS strategy to create a healthcare system in the US that results in better accessibility, quality, affordability, empowerment, and innovation.

Pack4U’s goal is to improve patient health outcomes at scale by collaborating with physicians. We introduce simple to use technology to your patients, monitor in real-time with clinical pharmacists, and provide monthly reports to simplify the billing process – making now the time to incorporate RPM services into your busy physician practice.