Remote Physiologic Monitoring In Light of Recent CMS CPT Codes and Clarifications

By Kyle Sutliff
Monday, April 29, 2019

In a world of expanding telemedicine and home healthcare, confidence in receiving adequate physician reimbursement for remote patient monitoring (RPM) services that has traditionally been less than ensured may now become a regular occurrence.


Kyle Sutliff

Due to numerous factors including improved patient monitoring technology and communication software, an aging population and the Centers for Medicare and Medicaid Services’ (CMS) acknowledgement of transportation related hardships, as well as a general shift in patient and physician preferences towards preemptive care and convenience, CMS has — as of Jan. 1 — implemented a new set of CPT codes (99453, 99454 and 99457) to guide providers and ensure they get paid for establishing, monitoring and providing patient instructions for remote monitoring devices. These codes offer medical providers the ability to receive adequate reimbursement for activities like walking a patient through the use and care of monitoring devices, including devices measuring blood pressure, pulse oximetry, or respiratory flow rate, review of the information from said devices (whether daily or by programmed alert), monthly follow-ups with patients regarding such information, and other similar patient care and management services.

Prior to the new codes, RPM services had been reimbursable under the 16-year-old code 99091 (previously used for the collection and interpretation of similar physiologic data digitally stored and transferred). The new codes are more easily satisfied and also broken into one of three separate parts to more accurately reflect how RPM services are currently being provided. First, 99453 provides reimbursement for patient instruction and the initial set up of the recording equipment. Code 99454 covers successive monitoring of the devises, and, finally, code 99547 allows for reimbursement of interactive communications between the patient and qualified health professionals regarding information gathered from the devices without the requirement of a face-to-face interaction.

Additionally, while the term “qualified health professionals” under code 99091 included physicians and “similar providers,” the new codes expanded who is able to provide care, including clinical staff, such as registered nurses, and even some medical assistants depending on the scope of State law and supervision requirements. This ease of use was further expanded as of March 15, when CMS released a technical clarification, which removed a sentence from the January publication which prohibited billing for these codes when “furnished by auxiliary personnel incident to a practitioner’s professional services.” The correction expressly states that such “incident to” billing is permitted given the appropriate direct supervision normally required for such billing.

The new codes are also more easily met in that code 99091 required providers to track their services on a revolving 30-day period and provide a minimum of 30 minutes of RPM services per a 30-day period. Services under the new codes are tracked on a simple month-tomonth basis and only require 20 minutes of RPM services to seek reimbursement. Even with all these improvements, two issues that are not discussed in the Final Rule but should nonetheless be complied with are; (i) obtaining patient consent, which was required under code 99091 and absent contradiction from CMS should be expected to apply to the new codes, and (ii) all other Medicare service requirements including applicable patient co-pays.

Finally, we are still waiting on clarification from CMS regarding the kinds of technology that can be utilized under the new codes. For example, safe practice absent clarification would be to rely exclusively on equipment meeting the FDA definition of “medical devices,” however, many advocates are hoping for CMS to expand the scope of RPM devices to include even more convenient technology such as the patients’ smartphones or Fitbits. As of now, CMS has only responded that they “plan to issue guidance to help inform practitioners and stakeholders on these issues.”

In summary, providers currently monitoring their patients, using existing chronic care management codes, which can be billed concurrently with RPM codes, and those seeking to expand into RPM services should familiarize itself with these new codes and keep their eyes open for CMS guidance which might give rise to a variety of new ways to expand their practice and allow for more convenient patient care.

Kyle Sutliff is an associate at CCBLaw, a boutique law firm focused on providing counsel to physicians and other healthcare professionals. He can be reached at 315-477-6261 or ksutliff@ccblaw.com.