Population Health Insights

2019 Medicare Physician Fee Schedule Could Expand RPM Reimbursement


Just as it did for the 2018 calendar year, the Centers for Medicare & Medicaid Services (CMS) is seeking to further expand reimbursement for remote patient monitoring, virtual visits and other telehealth services as part of its proposed 2019 Medicare physician fee schedule.

In what it’s calling a “historic” change to “modernize Medicare and restore the doctor-patient relationship,” the CMS is proposing these changes to “support access to care using telecommunications technology” — specifically, by:

  • Expanding reimbursement allowances for RPM services already in place with CPT 99091, which was unbundled in 2018 to allow separate billing for remote care services
  • Offering greater reimbursement for virtual visits, which the CMS calls “brief, non-face-to-face appointments via communications technology”
  • Including the remote evaluation of patient-submitted photos as a reimbursed service
  • Expanding the range of Medicare-covered services “to include prolonged preventive services

“Getting to the doctor can be a challenge for some beneficiaries, whether they live in rural or urban areas,” the CMS statement reads. “Innovative technology that enables remote services can expand access to care and create more opportunities for patients to access personalized care management as well as connect with their physicians quickly.”

2019 Medicare Physician Fee Schedule: 3 Key Takeaways

Specific to RPM reimbursement expansion, the proposed 2019 Medicare physician fee schedule changes “are intended to better reflect how RPM services can be delivered to patients,” as healthcare regulatory attorney and long-time telemedicine advocate Nathaniel Lacktman told Xtelligent Media’s Eric Wicklund. Lacktman goes on to outline in detail three major ways it would do so:

  1. Reducing the amount of treatment time required for reimbursement eligibility. As Lacktman points out, the recently unbundled CPT code 99091 “requires at least 30 minutes per 30-day period,” whereas the new code — CPT 994X9 — requires just 20 minutes within the span of a calendar month.
  1. Allowing for separate payment for time spent on initial set-up and patient training and education — something CPT 99091 doesn’t offer. Lacktman calls this “a very helpful move to further incentivize providers to start using these technologies with their patients.” 
  1. Extending RPM reimbursement eligibility to a physician’s or practice’s clinical staff. Currently, CPT 99091 is limited to the treating physician and certain specifically qualified professionals, “and does not expressly allow the RPM service to be delivered by clinical staff (e.g., RNs, medical assistants, etc.),” Lacktman told Wicklund.

“This means the physician or qualified health care professional must perform the full 30 minutes per 30-day period, which is a lot of time for these highly trained professionals,” Lacktman continues. “For some providers, this is too resource-intensive to justify the $58.68 per month reimbursement rate. The new code allows RPM services to be performed by clinical staff.”

Advice to Providers Seeking RPM Reimbursement Expansion

On top of these changes, the proposal signals a shift to the more widespread use of asynchronous technology in remote care delivery, as opposed to the strictly real-time communications represented by virtual visits — something that Lacktman believes to be “the future” of telehealth.

“A growing number of states allow a valid doctor-patient relationship to be created via asynchronous telemedicine in a clinically-appropriate manner,” he adds. “We are seeing notable use of this technology not only in direct-to-consumer telemedicine, but also among hospitals and academic medical centers, who often refer to them as ‘eConsults’ and have realized astonishingly high satisfaction ratings from patients and providers alike who use this technology.”

The CMS itself is promoting the 2019 Medicare fee schedule change as inducive to improved satisfaction rates, as well as improved relationships between patients and their caregiversa long-heralded benefit of remote patient management.

The changes “would fundamentally improve the nation’s healthcare system and help restore the doctor-patient relationship by empowering clinicians,” the CMS statement points out. This, in turn, “bring us one step closer to a modern healthcare system that delivers better care for Americans at a lower cost,” U.S. Department of Health and Human Services Secretary Alex Azar said in the statement.

“Today’s proposals deliver on the pledge to put patients over paperwork by enabling doctors to spend more time with their patients,” CMS Administrator Seema Verma agreed, adding that the changes streamline “documentation requirements to focus on patient care” and modernize payment policies so those “covered by Medicare can take advantage of the latest technologies to get the quality care they need.”

How RPM Reimbursement Expansion Is Helping the Transition to Value-Based Care

Lacktman agrees with this positive assessment, telling Wicklund that he was “overjoyed to read the proposed rule,” calling it “a landmark change allowing providers to much more meaningfully use new technologies when delivering medical care.” 

Also in agreement is Care Innovations® Chief Operations Officer Marcus Grindstaff, who recently wrote that reimbursement expansion can help “bridge the gap” between fee-for-service and value-based care — the two models between which many healthcare providers are currently fluctuating, often unsuccessfully.

With the new Medicare fee schedule, “health systems can keep more patients out of the hospital by delivering remote monitoring programs to a much larger population, and ensuring that they are made whole on all their patients,” he continues. “This has already started with CPT 99091, and will accelerate into 2019. The leading remote care delivery organizations will be well prepared for this service addition.

And that preparation means taking advantage of the CMS’ public comment process, a point that Lacktman emphasizes to Wicklund. “Do not wait until after the final rule is published, only to complain that CMS didn’t consider something important,” he said. “You need to help CMS by informing them through the public comment process.

If you’re interested in learning more about how the 2019 Medicare Physician Fee Schedule can help your practice or organization expand its use of remote patient management, we’re standing by to answer your questions: Contact us here to schedule a complimentary consultation with a Care Innovations® telehealth specialist.

Contact Care Innovations