On November 2, 2023, the Centers for Medicare & Medicaid Services (CMS) put into effect new policies around remote physiologic monitoring (RPM) and remote therapeutic monitoring (RTM) services refunded under the Medicare program. With these new rules established, companies need to be aware of the top five policies concerning Medicare’s RPM and RTM for 2024.
Significant changes were made in the 2024 Physician Fee Schedule final rule published by Foley & Lardner LLP. The rules primarily address billing scenarios and provide clarification requests on the appropriate use of these remote monitoring codes.
- Rules around RPM Services: CMS clarified that RPM services can be ordered and provided by auxiliary personnel under the general supervision of a practitioner. However, these personnel must act in compliance with applicable state law, scope-of-practice laws, and licensure rules.
- Frequency of RPM Services: CMS gave specifics on the frequency of RPM services, confirming that they could be billed no more than once every 30 days except for CPT code 99454, which can be billed daily.
- Revised Definitions for RPM and RTM: CMS revised and distinguished the definitions of RPM and RTM. Based on the 2024 rules, RPM pertains to “physiologic” treatment, while RTM relates to “therapeutic” care.
- Consent for RTM Services: CMS provided guidelines that patients must give consent for RTM services annually. This can be acquired at the same time with the consent for treatment or other services.
- Billing Amounts: Changes were made to the amounts that can be billed for RPM and RTM services with the intention of providing a balanced approach to patient care.
Companies and professionals involved in delivering these remote monitoring services must pay due diligence to these new rules for Medicare to safeguard not only the interests of the organization but to also provide patient care within the defined CMS guidelines. Understanding and following these rules can greatly aid organizations in streamlining their operations and avoiding potential complications with compliance issues.