In the Fall of 2018, Medicare approved the rules for how they would pay for three new remote physiologic monitoring (RPM) codes. These codes mark significant progress in payment for patient care occurring outside of the office. There are requirements to learn, but they make sense for physicians and other qualified providers working with their staff in the care of patients with chronic disease.
Indeed, as currently constructed, RPM makes more sense for the small practice than it does for the larger network, with resources shared across multiple locations. Perhaps it runs against the trends in the business of primary care lately, but under the rules for 2019, RPM’s leaders may look like the “Marcus Welby” model of a physician and their team, working closely together in a single office to take care of their patients.
The three new RPM CPT® codes are:
- 99453 - Remote monitoring of physiologic parameter[s] [e.g., weight, blood pressure, pulse oximetry, respiratory flow rate], initial set-up and patient education on use of equipment.
- 99454 - Device[s] supply with daily recording[s] or programmed alert[s] transmission, each 30 days.
- 99457 - Remote physiologic monitoring treatment management services, 20 minutes or more of clinical staff/physician/other qualified health care professional time in a calendar month requiring interactive communication with the patient/caregiver during the month.
These codes can be used in the care of established patients with chronic disease, using FDA cleared monitoring devices.
The 99457 code for the professional service can be billed in any calendar month where the billing clinician and their staff put in 20 minutes of work outside of the office visits. This framework will enable innovation around tools that more closely connect the patients with their care teams between office visits, monitoring health status and hopefully making more timely interventions.
For now, that innovation favors the small clinic. The current rules require that staff who contribute time to the professional service billing work under “Direct Supervision.” In Medicare, “Direct Supervision” is understood as staff working at the same time, in the same clinic—the same physical location. Understood functionally, the staff doing this work can immediately consult the billing clinician in person. That’s perfect for the “good ole fashioned” doctor and their nurse or two, working in a community-based practice.
The “modern provider network,” especially in the days of an EMR on an IT network, will share resources (like a diabetes care management team) working centrally for patients across many locations. Today’s Medicare RPM doesn’t work as well for them. While this may change in the future, for now we may well see the “dinosaurs” leading us into the use of the latest, internet-connected, patient monitoring tools. Recent studies suggest these practices may deliver outcomes as good as, or better than, their network counterparts on a number of important aspects of care. Maybe RPM will be another.