Why Reimbursement Changes are Making Telehealth and Remote Patient Monitoring a Necessary Strategy For Healthcare Organizations

by | Apr 26, 2022 | Industry Resources, Products and Solutions, Thought Leadership

Since the start of the COVID-19 pandemic in 2019, the healthcare industry has changed significantly. Perhaps nowhere is that change more noticeable than in telemedicine. Prior to the pandemic, telehealth and remote patient monitoring (RPM) were growing slowly. COVID-19 not only changed the world but changed how healthcare is conducted. Telehealth is developing rapidly and set to take on a greater role in the years to come.

This report will explore the impact of regulatory and reimbursement changes on telehealth, how advancements in technology are pushing RPM forward, and why the future of telehealth and RPM make it a necessary strategy.

Recent Regulatory and Reimbursement Changes

While the pandemic played a role in the rise of telemedicine, it also benefited from subsequent regulatory changes regarding how telehealth and remote patient monitoring (RPM) is reimbursed. The Centers for Medicare and Medicaid Services (CMS) first began reimbursing RPM services in 2019 and has expanded coverage each of the following years.

Among the initial changes that helped fuel extensive growth of telehealth was the expansion of services toward patients with acute conditions, as well as those with chronic conditions. CMS also approved RPM services for new patients as well as established patients.

CMS expanded coverage of telehealth services again in January 2022 by removing access barriers and increasing access to mental healthcare nationwide. Specifically, it amended the definition of interactive telecommunications systems for telehealth services to include audio-only communications technology when used for telehealth services for the diagnosis, evaluation, or treatment of mental health disorders furnished to established patients in their homes under certain circumstances.

CMS also further expanded remote monitoring coverage by recognizing remote therapeutic monitoring (RTM) services. The new RTM codes will help bridge gaps present in the current RPM coverage. And while the RTM codes share some big resemblances with the RPM codes, there are key differences.

  • Remote therapeutic monitoring includes non-physiologic data monitoring currently outside the RPM scope, including medication and pain adherence, musculoskeletal system status, medication response, and respiratory system status.
  • RPM offers payment parity, with the same pay rates for some RTM services, which is a positive for qualified health care professionals and therapists.
  • RTM covers self-reported data monitoring as part of non-physiologic data. This is a major difference compared to the RPM codes, which specific data should be automatically transmitted through connect devices.
  • RTM is designed for a broader range of providers, allowing practitioners who are unable to order and bill for services under the RPM codes.

Remote Patient Monitoring (RPM) CPT Codes

CodeOverviewDescription
CPT Code 99453Initial set-up and patient education on use of the equipmentRemote monitoring of physiologic parameter(s) (e.g., weight, blood pressure, respiratory flow rate), plus initial set-up and patient education on the use of equipment.
CPT Code 99454Device(s) supply with daily recording(s) or programmed alert transmission, each 30 daysDevice(s) supply with daily recording(s) or programmed alert(s) transmission, every 30 days. (Initial collection, transmission, and report/summary services to the clinician managing the patient)
CPT Code 99457Monitoring/Treatment Management Services, first 20 minutesRemote physiologic monitoring treatment management services, clinical staff/physician/other qualified health care professional time in a calendar month requiring interactive communication with the patient/caregiver during the month; first 20 minutes
CPT Code 99458Monitoring/Treatment Management Services, each additional 20 minutesEach additional 20 minutes (List separately in addition to code for primary procedure.)
CPT Code 99091Collection and interpretation of physiologic data, each 30 daysCollection 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, qualified by education, training, licensure/ regulation (when applicable) requiring a minimum of 30 minutes, every 30 days.

Remote Therapeutic Monitoring (RTM) CPT Codes

CodeOverviewDescription
CPT 98975Initial set-up and patient education on use of the equipmentRemote therapeutic monitoring (e.g. respiratory system status, musculoskeletal system status, therapy adherence, therapy response); initial set-up and patient education on use of equipment
CPT 98976Device(s) supply with daily recording(s) or programmed alert transmission, each 30 days (Monitoring Respiratory System)Remote therapeutic monitoring (e.g. respiratory system status, musculoskeletal system status, therapy adherence, therapy response); device(s) supply with scheduled (e.g. daily) recording(s) and/or programmed alert(s) transmission to monitor respiratory system, each 30 days
CPT 98977Device(s) supply with daily recording(s) or programmed alert transmission, each 30 days (Monitoring Musculoskeletal System)Remote therapeutic monitoring (e.g. respiratory system status, musculoskeletal system status, therapy adherence, therapy response); device(s) supply with scheduled (e.g. daily) recording(s) and/or programmed alert(s) transmission to monitor musculoskeletal system, each 30 days
CPT 98980Monitoring/Treatment Management Services, first 20 minutesRemote therapeutic monitoring treatment, physician/other qualified health care professional time in a calendar month requiring at least one interactive communication with the patient/caregiver during the calendar month; first 20 minutes
CPT 98981Monitoring/Treatment Management Services, each additional 20 minutesRemote therapeutic monitoring treatment, physician/other qualified health care professional time in a calendar month requiring at least one interactive communication with the patient/caregiver during the calendar month; each additional 20 minutes

Changes made by CMS have not always benefited healthcare providers. Though the RPM program is popular, in January of 2022 CMS made small cuts to the reimbursement rates of RPM services, from billable time to device use. The following chart details the differences between the established reimbursement in 2021 and 2022.

2021
Device Based RPM
2022
Device Based RPM
99454 $6599454 $56
2021
RPM Setup/Education
2022
RPM Setup/Education
99453 $2199453 $20
2021 Time Based RPM2022 Time Based RPM
20-Minutes99457 $5499457 $52
40-minutes99458 $4399458 $40
60-minutes99458 $4399458 $40

Further Need for Regulatory and Reimbursement Changes 

While the changes CMS made during the pandemic have helped both patients and providers, there is still a need for continued improvement. The hybrid healthcare landscape will persist past the COVID-19 pandemic, however many of the regulatory and reimbursement changes are only temporary. As a result, the future of telehealth regulations and reimbursement is unclear, leaving healthcare providers in a difficult position.

For example, many of CMS’ RPM updates are tied to the public health emergency (PHE) put in place at the start of the COVID-19 pandemic. The PHE is currently scheduled to end in July, but CMS has stated that some services will remain in effect until the end of 2023. Many healthcare leaders called on Congress to make the regulatory changes permanent. In March, Congress fell short of these calls by passing a bill temporarily extending the telehealth flexibilities for Medicare by 151 days after the end of the PHE.

Here is a list of major telehealth and remote patient monitoring flexibilities currently set to expire:

  • Enabling Medicare patients outside of rural areas to receive care via telehealth. Prior to the pandemic, telehealth services were only covered in Medicare for patients in rural areas, with limited exceptions. Temporary flexibilities enabled all Medicare patients to receive care via telehealth.
  • Remote patient monitor services available for patients with acute care and chronic conditions. Under a PHE waiver, RPM services can be considered medically necessary for patients with acute conditions as well as patients with chronic conditions. This exception is set to expire after PHE.
  • Remote patient monitoring services available to both new and established patients. Under a PHE waiver, RPM services were permitted to both new and established patients. After PHE ends, practitioners will need to conduct a new patient evaluation and management (E/M) service prior to ordering RPM services. How telehealth can be used with new patients isn’t exactly clear. To date, CMS has not issued public guidance on using telehealth to conduct new patient E/M service prior to enrolling a beneficiary in an RPM program. However, for Medicare telehealth services, CMS does allow audio-video technology to satisfy the face-to-face element of E/M services. Additionally, CMS generally defers to state laws on professional practice requirements, clinical standards of care, and valid doctor-patient relationships. Many state laws allow for telehealth use to create a valid doctor-patient relationship for new patients.
  • Enabling Medicare patients to receive telehealth services from their home. Prior to the pandemic, most telehealth services were only covered when the Medicare patient traveled to and received the service from a qualified medical facility. A temporary flexibility enabled these patients to receive telehealth services from their homes.
  • Enabling any Medicare-enrolled provider to bill for telehealth services. Prior to the PHE, Medicare would generally only cover telehealth services provided by physicians and certain other practitioners.
  • Allowing Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) to serve as distant sites. Prior to the PHE, FQHCs and RHCs could not provide services via telehealth. During the PHE, FQHCs and RHCs were considered eligible distant sites. (CMS has made this permanent for behavioral health services.

Telehealth by the Numbers
Prior to the pandemic, approximately 12,500 Medicare beneficiaries received telehealth services. By October 2020, more than 24.5 million Medicare beneficiaries received telehealth services.
More than 75% of hospitals and clinics believe RPM adoption will be on par or surpass inpatient monitoring in the next five years.
Insider Intelligence estimates 70.6 million U.S. patients, or 26% of Americans, will use remote patient monitoring tools by 2025.
University of Pittsburgh Medical Center leveraged RPM to reduce the risk of hospital readmissions by 76%.
RPM also help the University of Pittsburgh Medical Center keep patient satisfaction scores over 90%.
A survey by McKinsey found that 76% of patients would be interested in using telehealth moving forward.


Telehealth Advancing Beyond Devices and Remote Access

Telehealth regulations and reimbursements are not the only changes taking place. How healthcare organizations view telemedicine is also evolving. It has moved beyond simply connecting patients to doctors remotely and is now more fully integrated into a healthcare organization’s patient care strategy.

RPM provides a perfect example for this shift in strategy. Prior to the pandemic, RPM was solely viewed as the devices used to monitor patients remotely. There was little strategy around how those devices integrated into the large healthcare process. In fact, patients would often have to navigate multiple devices and platforms, connect the data themselves, and then share the information with their physicians. Today, leading healthcare organizations are approaching RPM as part of their unified healthcare solution. Digital apps, Bluetooth devices, and wearable monitors are becoming more integrated, taking the onus and responsibility out of the patient’s hands.

Several areas where Healthfully is helping make advancements to telehealth and RPM include:

  • Integration with a provider’s existing electronic medical systems
  • Compatibility with a patient’s existing wearable health monitoring software or devices
  • Ease-of-use for patients and doctors (single-sign-on)
  • Expansion of capabilities to include transitional, chronic, and acute care
  • Multi-platform compatibility
  • Combined patient and wellness record

Specialties that Benefit the Most from Telehealth & RPM
While many specialties benefit from telehealth and RPM, there are a few specific areas of focus. The specialties with the highest rate of telehealth adoption offer care management for patients with chronic conditions. Allergy & Immunology
Cardiology
Dermatology
Emergency Medicine
Endocrinology
Geriatrics
Family Medicine
Infectious Diseases
Internal Medicine
Neurology
Occupational Medicine
Ophthalmology and optometry
Pathology
Pediatrics
Pediatric Pulmonology
Psychiatry
Radiology
Urology

Widespread Adoption of Telehealth & Remote Patient Monitoring 

While regulatory and reimbursement changes jump started the focus on telehealth, widespread adoption is being driven by a fundamental shift in its use. Prior to the pandemic, telehealth was seen as a tool primarily used for rural areas or for managing low-complex issues, like a cough or cold. However, today telehealth’s value is focused on chronic-disease management. It reduces the need for all patients, not just those in a rural setting, to constantly travel in and out of doctors’ offices. It also reduces stress on patients, leading to better health outcomes.

The adoption of RPM was already underway prior to the pandemic, driven primarily by increasing consumer expectations. However, the risk of COVID-19 exposure combined with decreasing healthcare resources amplified its usage among patients and providers.

As COVID-19 cases begin to drop and the risk of exposure decreases, the demand for RPM remains elevated. In fact, a recent Harris Poll found that:

  • 80% of Americans want the ability to use technology when managing their healthcare experience. 
  • 59% of Americans said a convenient experience is more important than having a designated provider.
  • 70% of Americans said they would consider switching to a provider that offered more appealing services.

The Harris Poll confirmed what most healthcare leaders already suspected. Patients are demanding more personalized, data-driven virtual care. The challenge for healthcare providers is to find a solution that delivers on patients’ expectations without driving up costs.
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Benefits of Telehealth and Remote Patient Monitoring

Telehealth and RPM provide a wide range of benefits to healthcare organizations, including:

  1. RPM makes healthcare easily available. Providers can connect with patients anywhere. It makes office visits unnecessary, allowing healthcare organizations to gain more visitors without overcrowding facilities.
  2. RPM Reduces Burden on Physicians.  Through RPM technology, 90% of the workload associated with patient engagement can be delegated to a qualified Care Manager.  As such,  RPM plays a key role in providing physicians with more leverage while reducing their day-to-day workload.
  3. RPM saves money. According to a report by the Federal Communications Commission (FCC), the healthcare industry could save $700 billion in the next 15-20 years with the use of RPM technology. Healthcare organizations can also save on operational costs by reducing re-admissions and lengths of stay, increase staff engagement, and decrease in-person patient visits.
  4. RPM improves healthcare quality. RPM directly connects clinicians with patient data, improving the quantity and quality of care. It increases patient engagement while improving management of acute and chronic conditions. It also reduces clinician burnout by enabling clinicians to work more efficiently.
  5. Enhances doctor-patient communication. RPM encourages a stronger doctor-patient relationship, fostering transparency and trust. The data offers physicians a deeper understanding of conditions and treatment and enables patients to take a more active role in their care plans.
  6. Delivers the personal and proactive care patients expect. Patients are demanding a healthcare experience that resembles the consumer experience they’ve become accustomed to. A comprehensive approach to RPM allows patients and physicians to track vitals, get specific analysis, and get answers to health questions.

Key Requirements for an effective telehealth and RPM program

  1. Understand and compare the different systems
    Research Medicare codes as well as CMS codes. Follow guidelines to ensure accurate billing practices and reduce the risk of claim denials.
  2. Define your requirements
    Choose a system by carefully considering which services your patients and organization require, the system’s difficulty, equipment, billing services, as well as service type.
  3. Describe the system to your patients and explain its importance
    After defining your requirements you can provide a better understanding of the system and its importance to your patients. Communicate its benefits and the conditions it will help them manage.
  4. Provide ongoing guidance to your patients
    A successful RPM program requires providing continuous instructions to patients including teaching them how to use the system correctly. Deliver education through various channels to cater to varying patient needs. Patients need to be confident with the technology, motivated to participate, know how to contribute to their care, and feel empowered to overcome any problems they encounter.

Conclusion

The regulatory and reimbursement changes enacted by CMS indicate that telehealth and RPM are becoming an important part of care delivery. While more advancements need to be made, telehealth and RPM have the true potential to engage patients, improve clinical outcomes, and reduce costs.

As an industry leader in digital health solutions, Healthfully is ready to support your organization’s patient satisfaction initiatives. Healthfully’s unified platform was designed to provide a better patient experience across the continuum of care, not just clinical services. For more information on how Healthfully can help meet your patient needs, or if you would like a demo of the platform, contact us at info@healthfully.io.

Mark Boudreau
Co-founder Mark Boudreau is the COO of Healthfully and brings more than 30 years of success across the technology, product and service, and healthcare industries. Mark previously served as a partner at Accenture and Vice President of Strategy at Orion Health.