The Centers for Medicare and Medicaid Services (CMS) finalized the Medicare Physician Fee Schedule for 2022 (MPFS).
As we noted in our October post, CMS proposed creating five new CPT codes and associated opportunities for reimbursement for Remote Therapeutic Monitoring (RTM). On November 2nd, 2021 these codes were finalized and will become effective January 1st 2022.
Along with the exciting RTM news, CMS has finalized its payment update for Chronic Care Management (CCM) and the 10 corresponding CPT codes. CMS’ emphasis on increasing access and payments for CCM shows the importance of this program as a part of a long-term strategy based around preventive measures to this high-risk patient population.
Remote Therapeutic Monitoring
RTM is the collection and monitoring of therapy adherence and therapy response data along with treatment management services. RTM can be used for non-physiological medical devices like those used to support medical adherence (e.g., smart pill reminder systems) and medication symptom/adverse reaction applications.
Unlike the Remote Patient Monitoring code set categorized as Evaluation and Management (“E/M”) codes in the CPT Manual, the five codes finalized for Remote Therapeutic Monitoring are general Medicine codes, billable by practitioners who are not eligible, in addition to providers who are eligible to bill evaluation and management services.
Remote Therapeutic Monitoring CPT Codes
==> Initial Set-up and Patient Education: CPT code 98975 (Remote therapeutic monitoring (e.g., respiratory system status, musculoskeletal system status, therapy adherence, therapy response); initial set-up and patient education on use of equipment)
==> Supply of Device for Monitoring Respiratory System: CPT code 98976 (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)
==> Supply of Device for Monitoring Musculoskeletal System: CPT code 98977 (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)
==> Monitoring/Treatment Management Services, first 20 minutes: CPT code 98980 (Remote therapeutic monitoring treatment management services, 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)
==> Monitoring/Treatment Management Services, each additional 20 minutes: CPT code 98981 (Remote therapeutic monitoring treatment management services, 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 (List separately in addition to code for primary procedure))
Increased reimbursement and access to CCM
CMS stated that it is significantly increasing reimbursement for the 10 chronic care management CPT codes, because it is "consistent with our goals of ensuring continued and consistent access to these crucial care management services and acknowledges our longstanding concern about (the) undervaluation of care management under the physician fee schedule."
These changes show the increasing support CMS has for CCM. Along with the added reimbursement structure, CMS has added five new CPT codes that increase access to CCM.
CCM, clinical staff, initial 20 min.
CCM, clinical staff, additional 20 min.
CCM, physician/NPP, initial 30 min
CCM, physician or NPP, additional 30 min.
CCCM, clinical staff, 60 min
CCCM, clinical staff, +30 min
99424 (formerly G2064)
PCM, physician or NPP, first 30 min.
PCM, physician or NPP, additional 30 min
99426 (formerly G2065)
PCM, clinical staff, first 30 min.
PCM, clinical staff additional 30 minutes
TCM and CCM Billing for RHC/FQHC’s
Currently, RHCs and FQHCs may not bill for TCM services for a beneficiary if another practitioner or facility has already billed for CCM services for the same beneficiary during the same time-period.
Patients receiving TCM services after discharge would benefit from the more comprehensive care management plan developed under CCM. CMS agreed and has allowed for RHC/FQHC’s to bill for TCM and other care management services for the same beneficiary during the same service period, provided that all requirements for billing each code are met.
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