The greatest departure from prior policy is reimbursement for remote patient monitoring. In the past, CMS has only offered payment for live, audiovisual virtual visits. Here are the three main takeaways from the rule on what this shift means for the future of virtual care.
1. Medicare is particularly interested in telehealth's role in complex care management.
Several government research reports have found benefits of remote patient monitoring, especially in reducing 30-day readmissions and associated costs. The creation of CPT code 99091 signals CMS's recognition of this strong evidence base.
2. Tele-monitoring requires more care team members than just physicians.
CPT code 99091 is open to reimbursement across multiple providers—a "physician or other qualified health care professional" may bill for services. This approach aligns with the use of providers like care managers and nurses to monitor and analyze data outputs from monitoring devices.
3. Remote patient monitoring should be a complement to in-person services.
The final rule states that remote patient monitoring is "complementary" to ongoing care management services and may be billed alongside three chronic care and four behavioral health codes focused on long-term patient management. In highlighting the separate but coordinated nature of these services, CMS reinforces that remote monitoring is most effective when combined and integrated with ongoing care services. While tele-monitoring can flag changes in patient function, care management support is necessary to effectively incorporate that information into the treatment plan.
A dedicated remote monitoring code is a progressive shift for CMS, but the low reimbursement rate ($60 per patient per month) fails to cover the practical costs for most programs. Though this code offsets some expense, the current rate will likely limit large-scale deployment under fee-for-service models. For the near future, this telehealth modality remains most viable for the treatment of high-risk patients under value-based payment programs.
But given the slew of federal telehealth legislation in 2017 involving tele-monitoring, such as the HEART and Medicare Telehealth Parity Acts, CPT code 99091 is likely a short-term rather than permanent solution. Remote patient monitoring should remain a hot topic in 2018—look out for continued efforts to expand tele-monitoring to new patient groups and further analysis of the reimbursement rate under CPT code 99091.
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