CMS Releases 2021 Final Rule with Changes to RPM and CCM

On December 2, 2020, the Centers for Medicare and Medicaid Services (CMS) released the 2021 Fee schedule final rule.

While the official document from CMS is over 2,000 pages, it has become a tradition for us to simplify these changes for our clients and the general public

CMS has made changes to both Chronic Care Management (CCM) and Remote Patient Monitoring (RPM).

CMS added much needed clarification to several aspects of the RPM rules and held off on making 2 changes that could’ve made this program unmanageable for certain providers.

In this article, we’ll break down these changes and how your practice can leverage them to help increase your revenue and improve the quality of care you provide.

Changes to RPM for 2021

1) Clarification of days required for 99454

As a reminder, code 99454 is billed for the provided RPM device with daily monitoring for a total of $65.00.

Since CMS added this code, there has always been some confusion about how many readings (or days of readings) are actually required to bill for 99454.

CMS used the word “daily”, but what if a patient missed a day, or several days of readings?  

Many experts released statements that 16 days of readings was the appropriate number. This number was not published in last year’s final rule nor was it referenced in any official publications from CMS.

This year, CMS cleared up the confusion around this rule: 16 days of readings are required in order to bill for 99454 or 99453.

How COVID-19 Impacts This Ruling

While CMS has confirmed that 16 days of readings are required to bill for 99454 or 99453, exceptions have been made due to COVID-19.

In the summer of 2020, CMS announced that due to the Public Health Emergency (PHE) for COVID-19, these codes would only require a minimum of 2 days of readings, rather than the required 16 days.

This exception also created confusion: does that minimum of 2 days of readings apply to all patients or only patients affected by COVID-19?

CMS has now clarified that the exception applies to all patients while the PHE is in effect.

It’s important to note that this exception only applies while the PHE is in effect. Once the PHE for COVID-19 expires, the required 16 days of readings will be back in effect.

For now, this is a great development which should make it easier for more patients to be billable for RPM each month.

2) Interactive Communication is not required for 99457

In the proposed rule for 2021, CMS hinted that the 20 minutes required for 99457 MUST be made up entirely of interactive communication.

We were extremely opposed to this restriction, as much of the day-to-day care management activities occur outside of interactive communication with the patient.

A large percentage of a care manager’s time managing RPM is spent reviewing numbers, planning calls, having discussions with providers, and other important tasks.

If this proposal were to be implemented, it would dramatically increase the burden on care managers, ultimately resulting in fewer patients being qualified for 99457 each month.

Thankfully, CMS has clarified that the 20-minutes for 99457 can include time for interactive communication as well as for furnishing care management services.

3) FDA clearance is NOT required for RPM devices

It has always been unclear as to whether RPM devices must be cleared by the FDA.

Since the FDA approval process can be lengthy, many great devices were being excluded from RPM because of this assumed requirement.

In the final rule, CMS confirmed that FDA clearance is NOT required as long as the device meets the FDA’s definition of a Medical Device.

This is great news for our clinics and will create many new opportunities to get state of the art devices in the hands of their patients.

4) Code 99458 is billable more than once

CPT code 99457 is for the first 20 minutes of RPM time each month.

For 2020, CMS added code 99458 to allow providers to bill for an additional 20 minutes of RPM per patient, per month.

There has always been a debate about whether 99458 had a limit of 1 instance per month. With a limit in place, RPM would be capped at 40 minutes each month.

In the 2021 Final rule, CMS clarified that 99458 is for “each additional 20 minutes.”

This means that there is no cap on the number of minutes that can be billed per patient per month for RPM.

Changes to CCM for 2021

While many of the changes have been made to RPM, CCM has seen a few updates itself.

1) New Code for 20-additional minutes: 99439

If you recall, for 2020, CMS added a new G-code, G2058, that could be used in conjunction with 99490 for providers who spent more than 20 minutes of CCM time per patient per month.

For 2021, G2058 will be replaced with code 99439.

For 2020, the CMS rules for CCM were as follows:

• At the 20 minute mark, use 99490 standalone as usual
• At the 40 minute mark, use 99490 w/ G2058
• At the 60 minute mark, use 99490 w/ G2058 (x2)

For 2021, the CMS rules for CCM have been amended to the following:

• At the 20 minute mark, use 99490 standalone as usual
• At the 40 minute mark, use 99490 w/ 99439
• At the 60 minute mark, use 99490 w/ 99439 (x2)

To help clarify this change, CMS has amended the definition of code 99490 from “20 minutes” to “first 20 minutes”. This rule change doesn’t affect providers too much, as this new CPT code 99439 is essentially replacing the G-code that CMS introduced in 2020.

For non-complex care, providers can still bill up to 60 minutes of CCM care per patient per month, in 20-minute increments.

2) CCM can be billed concurrently with TCM

Previously, CCM time couldn’t be billed in the same month for a patient that you are already billing TCM time for.

This change now allows you to bill for both TCM and CCM in the same month for the same patient when “reasonable and necessary”.

Implementing These Programs At Your Practice

These programs have always been extremely valuable to both patients and providers. With these new changes from CMS, 2021 is a perfect time to begin offering these programs to your patients if you aren’t already.

RPM Implementation

Successfully implementing RPM at your practice can improve patient health outcomes and offer a new revenue stream for practices, providing financial stability in uncertain times.

Our step-by-step guide provides a collection of best practices to ensure the successful implementation of an RPM program at your practice. The guide fully covers:

• Identifying a need and forming your team
• Setting goals
• Deciding to lease or buy RPM devices
• Identifying and recruiting eligible patients
• Training patients and clinicians
• Delivering RPM and engaging patients
• Coding, billing, and reimbursement

CCM Implementation

Similar to RPM, implementing CCM at your practice can provide many benefits. First and foremost, you’ll be providing much needed care to many patients.

CMS estimates that approximately one in four adults, including 70% of Medicare beneficiaries, have two or more chronic conditions, qualifying them to receive CCM.

Our CCM implementation guide walks you through the process of setting up a successful program, covering the following topics:

• Developing a plan and forming your care team
• Identifying and recruiting eligible patients
• Enrolling patients
• Delivering CCM and engaging patients
• Coding, billing, and reimbursement

How Care Management Software Helps Providers Manage Medicare Programs

If you’re looking to manage these programs successfully, care management software is highly recommended.

There are numerous benefits of utilizing a quality care management software solution, including consolidation of patient information, improved care coordination, increased patient engagement, and more.

The features and tools included in various software solutions are specifically designed to more effectively and efficiently manage Medicare programs.

ThoroughCare’s RPM and CCM software solutions provide extensive features and tools specific to those programs that make it the choice for hundreds of healthcare providers across the country.

Our solutions showcase an intuitive design built for clinicians, by clinicians. Our RPM software solution includes:

• Registration of patient devices, with support for integration with over 350 remote monitoring devices
• Tracking of multiple types of clinical data, from vital signs to blood glucose levels to work out details to sleep-related information
• Visualization of clinical readings from within the patient care plans, including the ability to view multiple measurements across user-defined timeframes to help clinicians identify patterns in their patient's data
• Configuration of target ranges (normal, caution, critical) for all data types, along with the ability to notify patients and clinicians through multiple communication channels (text, email, desktop notification) when patient readings fall outside of their physician's clinically-recommended range
• Time management and billing capabilities to support adherence to the CMS RPM service requirements

Our CCM Software solution includes:

• Your own secure, HIPAA-compliant software portal
• Unlimited users and patients
• Live Dashboard showing current CCM minutes
• Guided-interviews for CCM Care Plans
• Task tracker (with timer) and Time Logging
• Monthly Update interface for clinical staff and providers
• Create Care Plan reports for the patient and other providers
• Easily download summaries and upload to your EHR
• Integrates with Annual Wellness Visit Software
• Easy Billing interface to easily submit Medicare reimbursement claims
• Tech Support via email and phone

To give yourself the best chance of success, contact us to request a software demo of ThoroughCare’s software.