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.
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.
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.
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.
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.
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.
While many of the changes have been made to RPM, CCM has seen a few updates itself.
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:
For 2021, the CMS rules for CCM have been amended to the following:
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.
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”.
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.
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:
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:
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:
Our CCM Software solution includes:
To give yourself the best chance of success, contact us to request a software demo of ThoroughCare’s software.