Remote Monitoring Services
In the Final Rule, CMS provided a clarification on how remote physiologic monitoring (RPM) and remote therapeutic monitoring (RTM) are addressed and billed. CMS clarified the following points:
• After the PHE ends, RPM services are only for established patients. Patients who had received services during
the PHE are considered established patients. (Page Reference, p. 180).
• The 16-day monitoring requirement is reinstated after the PHE. See the specific details of the requirements for
each code’s description. (Page Reference, p. 180).
• Although multiple devices can be provided to a patient, the services associated with all of the medical devices
“can be billed only once per patient per 30-day period and only when at least 16 days of data have been
collected.” This applies even when multiple devices are used. (Page Reference, p. 182).
• Practitioners may bill RPM or RTM, but not both, concurrently with the following services:
o Chronic Care Management (CCM)
o Transitional Care Management (TCM)
o Behavioral Health Integration (BHI)
o Principle Care Management (PCM)
o Chronic Pain Management (CPM) (Page Reference, p. 182).
• RTM and RPM cannot be billed together (Page Reference, p. 183).
• Regarding global payment and how RTM and RPM maybe used, CMS notes that when a beneficiary’s
procedure/surgery and related services are covered by a global payment, RPM or RTM services may be
furnished separately and the provider will be paid for them separately from the global payment. If the
beneficiary is currently receiving services during a global period, the provider may also furnish RPM or RTM
services and the provider will receive a separate payment if the RPM/RTM services are unrelated to the diagnosis for the global procedure and are separate and distinct from the global procedure. See the 2024 Final Rule for more details. (Page Reference, 183).
More details and explanations are relayed in the Final Rule. (Page Reference, p. 178).
FQHC/RHC & RTM/RPM
CMS will include the CPT codes related to RPM and RTM in the general care management code HCPCS G0511 which will provide FQHCs/RHCs payment for RTM and RPM services. CMS noted that these services are similar to the Non face-to-face requirements for general care management services and reflect the additional resources needed to provide such services by an FQHC/RHC. (Page Reference, p. 760).
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