CMS Corrections to CPT Reimbursement Codes for RPM

For those among us who don’t reread the CMS codebook at every update, you should be aware of this:

A. Correction of Errors in the Preamble

1. On page 84545 of the CY 2021 PFS final rule, third column, the first partial paragraph at the top of the column is corrected by removing the following language:

 

The medically necessary services associated with all the medical devices for a single patient can be billed by only one practitioner, only once per patient per 30 day period, and only when at least 16 days of data have been collected.

2. On page 84545 of the CY 2021 PFS final rule, third column, prior to the first full paragraph, is corrected by adding the following language:

Comment: Commenters stated that for CPT codes 99457 and 99458, we interpreted “interactive communication” to mean “real-time synchronous, two-way audio interaction that is capable of being enhanced with video or other kinds of data transmission” and suggested that the required 20 minutes of time associated with CPT codes 99457 and 99458 should be only synchronous time, real-time between a practitioner and a patient. Commenters stated that these two codes include non-face-to-face time as well as real-time two-way audio interactions.

Response: We agree with commenters that our description of the required 20 minutes of time associated with CPT codes 99457 and 99458 should include care management services, as well as synchronous, real-time interactions. That is, we agree that “interactive communication” as we defined it in the CY 2021 PFS proposed rule contributes to the total time, but is not the only activity that should be included in the total time.

After considering comments, we are clarifying for purposes of this final rule, that the 20-minutes of intra-service work associated with CPT codes 99457 and 99458 includes a practitioner’s time engaged in “interactive communication” as well as time engaged in non-face-to-face care management services during a calendar month.

Comment: Commenters disagreed with our statement that the services associated with CPT codes 99453 and 99454 should be billed only once per patient, per 30-day period, and wrote that CMS should clarify that CPT codes 99453 and 99454 can be billed once per provider, per patient, per 30-day period.

Response: We thank commenters for their insights related to billing CPT codes 99453 and 99454. As we stated in the proposed rule, we believe these two codes should be reported for a patient only once during a 30-day period and only when reasonable and necessary. In response to public commenters, we are clarifying that only one practitioner can bill CPT codes 99453 and 99454 during a 30-day period and only when at least 16 days of data have been collected on at least one medical device as defined in section 201(h) of the FFDCA. CPT language suggests that even when multiple medical devices are provided to a patient, the services associated with all the medical devices can be billed only once per patient per 30-day period and only when at least 16 days of data have been collected. We also note that when a more specific code is available to describe a service, CPT indicates that the more specific code should be billed. We believe that there are additional, more specific codes available for billing that allow remote monitoring (for example, CPT code 95250 for continuous glucose monitoring and CPT codes 99473 and 99474 for self-measured blood pressure monitoring). In summary, we are clarifying that CPT codes 99453 and 99454 should be reported only once during a 30-day period; that even when multiple medical devices are provided to a patient, the services associated with all the medical devices can be billed by only one practitioner, only once per patient, per 30-day period, and only when at least 16 days of data have been collected; and that the services must be reasonable and necessary.

remote patient monitoring