- Fans of remote patient monitoring found a lot to like in new payment rules released last week by the Centers for Medicare & Medicaid Services, continuing what many hope is a trend toward CMS support for mHealth and telehealth technology.
Beginning in 2018, CMS will support clinicians who leverage remote monitoring tools, such as wearables and smart devices at home, and use patient-generated health data in care coordination and management.
The changes are included in CMS’ Merit-based Incentive Payment System (MIPS) improvements, which would enable doctors using “non-face-to-face chronic care management using remote monitoring and or telehealth technology” to receive Advancing Care Information (ACI) program points for activities like sending medication reminders, collecting, monitoring and reviewing patient physiological data and prescribing patient education.
The rules drew praise from the Connected Health Initiative, which had lobbied CMS for RPM incentives this past February.
"These new rules are an important step forward for America’s connected health innovators, doctors and, most importantly, patients,” CHI Executive Director Morgan Reed said in a statement. “Until now, connected health technologies have been effectively locked out of the most important part of America’s healthcare system, Medicare and Medicaid.”
“Previous CMS rules created serious disincentives for doctors to consider using new technologies,” Reed added. “Together with our advisory board, CHI pushed for newly enacted rules that finally level the playing field for innovators, giving doctors and patients the chance to take advantage of the best technologies available.”
CMS actually began this change in direction this past July, when it unveiled the 2018 Physician Fee Schedule proposed rule. And it laid the groundwork for an ongoing discussion on RPM that could lead to more coverage in the future.
Included in the PFS was a solicitation for comments on Current Procedural Technology (CPT) codes 99090 and 99091, which cover, respectively, “collection and interpretation of physiologic data (e.g., ECG, blood pressure, glucose monitoring) digitally stored and/or transmitted by the patient and/or caregiver to the physician or other qualified health care professional (QHCP), qualified by education, training, licensure/regulation (when applicable) requiring a minimum of 30 minutes of time” and “analysis of clinical data stored in computers (e.g., ECGs, blood pressures, hematologic data).”
The request for comments on those and other codes covering “extensive use of communications technology” signaled to mHealth advocates that CMS was thinking of switching gears on RPM and separating that platform from telehealth and telemedicine – two heavily regulated platforms that have drawn their own share of criticism for being too restrictive.
“This is huge,” says Robert Jarrin, Qualcomm’s Director of Wireless Health Public Policy and an expert in the digital health field. “They have articulated that RPM isn’t defined by telehealth.”
According to Jarrin, CMS has long classified RPM under “miscellaneous services” and included them in bundled payment programs. The technology could be grouped with other services that do have reimbursement codes, but is doesn’t have its own codes.
Beginning next year, CMS has unbundled CPT code 99091.
"Providers will soon be able to get reimbursed separately for time spent on collection and interpretation of health data that is generated by a patient remotely, digitally stored and transmitted to the provider, at a minimum of 30 minutes of time," Jodi G. Daniel and Maya Uppaluru, attorneys for the law firm of Crowell & Moring, wrote in a Nov. 3 blog.
Jarrin called both 99090 and 99091 “promising, but imperfect at best” in an August 2017 blog, and said he expects CMS to continue looking at ways to separate RPM from telehealth andf provide new avenues for reimbursement.
In addition, CMS iis adding several new telehealth services in 2018: counseling visit for lung cancer screening (HCPCS code G0296), psychotherapy for crisis (CPT codes 90839 and 90840), interactive complexity (CPT code 90785), patient- and caregiver-focused health risk assessment (CPT codes 96160 and 96161), and chronic care management services including assessment and care planning (HCPCS code G0506).
"These policy updates signal that CMS is moving quickly to incentivize the integration of innovative technologies as it pushes for the transition to value-based care," Daniel and Uppaluru wrote.."Health technologists can seize the opportunity to help hospital and clinician customers to meet their regulatory incentives by ensuring that digital health products conform to the requirements set out in these rules.
At the same time, the American Medical Association, which maintains and copyrights CPT codes, has signaled interest in developing RPM-friendly codes as well. That issue is currently being discussed by the AMA’s Telehealth Services Workgroup, which was launched in 2014, and the more recent Digital Medicine Payment Advisory Group (DMPAG).
That both CMS and the AMA are signaling an interest in RPM “really demonstrates how timely RPM is,” says Jarrin, who’s been a member of the DMPAG since its inception. “That acknowledges that this is a legitimate service.”
“A top priority for the DMPAG has been identifying pathways to clinical integration of digital medicine, specifically remote patient monitoring coding, valuation, coverage and program integrity,” Jarrin wrote in his blog. “As a result, several formal coding applications requesting the additions of new codes for physiologic monitoring and management have been submitted by the DMPAG to the CPT Editorial Panel for consideration during its upcoming September 2017 meeting. These applications include two for physiologic monitoring and management. One application requests the addition of a code to report the physician/provider services of chronic care monitoring/management of a patient using remote monitoring technology, the other addresses the technical component and set up.”
Jarrin says the AMA likely won’t reveal its direction until sometime next year, and any new codes won’t go live until 2019.
“There is no guarantee they will be approved by the CPT Editorial Panel, but digital medicine will not move forward unless it’s represented in the foundational medical nomenclature code set,” he wrote in his blog. “CPT’s partnership and understanding of the evolution of medical practice and current services are crucial. Should these codes gain approval, it doesn’t mean CMS will begin automatically covering or paying them. But the process of creating codes is methodical and requires thorough assessments of medical practice and procedures based on validated evidence, scientific backing from medical societies, the involvement of the medical community, well defined criteria, and clinical expertise.”
According to the Personal Connected Health Alliance, the issue now goes before the AMA’s Relative Value Scale Update Committee (RUC), which will work with medical specialty societies to develop accurate valuations and utilization figures for these services.
“In addition, the RUC makes recommendations to CMS on valuation of the codes for Medicare,” the PCHA reported. “This is a lengthy and rigorous process in which providers share data and information on the resources and clinical time associated with the delivery of the three defined components to remote patient monitoring for those with chronic conditions. The data on costs and clinical time associated with delivery of remote patient monitoring will be crucial.”