November 8, 2022
M&D Clinical Corner: Remote Physiological Monitoring – A Guide for Community Pharmacists
The Clinical Corner is a monthly feature that highlights a variety of important pharmacist topics that is written by Morris & Dickson’s staff pharmacist, Paula Belle (RPh).
This month’s Clinical Corner will provide an overview of Remote Physiological Monitoring (RPM). The topics we’ll cover in this article include the following.
- What is Remote Physiological Monitoring?
- Highlights of RPM
- Qualified Medicare patients and RPM devices
- How can pharmacists assist with RPM and generate revenue?
- Billing for RPM
What is Remote Physiological Monitoring (RPM)?
- Remote physiological monitoring (RPM) is the use of electronic devices to record a patient’s health data for a provider to receive and evaluate at a later time.[1]
- Remote patient monitoring (RPM) technology allows health care providers to use devices that gather and analyze health information without a face-to-face appointment or in-person testing.[2]
Highlights of RPM
- RPM offers several benefits to both patients and providers.[3]
- RPM allows providers to manage acute and chronic conditions.[3]
- RPM cuts down on patients’ travel costs and infection risk.[3]
- Benefits include:[3]
- Reduced hospitalizations
- Shorter hospital stays if the patient can be discharged with a remote monitoring device to use at home
- Fewer visits to the emergency room
- Better health outcomes for patients in rural areas
- Better preventative management for chronic conditions
- Reduced risk of COVID-19 exposure, along with other illnesses, for patients and health care workers
- There are many symptoms and conditions that can be tracked through remote patient monitoring, including[3]:
- The management of weight loss or gain
- Diabetes
- Heart conditions
- Asthma
- Chronic obstructive pulmonary disease (COPD)
- Sleep apnea
- High blood pressure
- Many of the devices that patients will use may be familiar to them, including[3]:
- Blood glucose meters
- Weight scales
- Pulse oximeters
- Blood pressure monitors
- Other conditions require more complicated devices that will require patient training, including[3]:
- Apnea monitors
- Heart monitors
- Specialized monitors such as for dementia and Parkinson’s disease
- Breathing apparatuses
- Fetal monitors.
- RPM services do not require a face-to-face visit or in-person testing. Therefore, these services are collected and stored remotely.[4]
- Medicare will reimburse eligible physicians and non-physician practitioners (NPP) who provide RPM services.[4]
Qualified Medicare Patients and Monitoring Devices
- Eligible providers can be reimbursed by Medicare for providing RPM services to their patients with both acute and chronic illnesses.[4]
- In order to qualify for Medicare reimbursement, the RPM device must meet several requirements[3]:
- Medical devices that digitally collect and transmit a patient’s physiologic data must be reasonable and necessary for the diagnosis or treatment of the patient’s illness or injury or to improve the functioning of a malformed body member.[3]
- The device must meet the FDA’s definition of medical device however, it does not have to be FDA-cleared/registered.[4]
- The devices must digitally (automatically) upload patient physiologic data and cannot be recorded or reported by the patient.[4]
- Medical devices must be used to collect and transmit reliable and valid physiologic data that helps describe the patient’s health status to develop and manage a plan of treatment.[4]
- A list of devices that meet the FDA definition of a medical device is available here: https://www.fda.gov/medical-devices/classify-your-medical-device/how-determine-if-your-product-medical-device
How Can Pharmacists Assist with RPM and Generate Revenue?
Are pharmacists allowed to perform RPM services?
- The CMS does not consider pharmacists to be qualified healthcare professionals. Therefore, pharmacists are not allowed to bill for RPM services.[6]
- CMS authorizes pharmacists to work in collaboration with providers and offer services as employees or contracted personnel.[6]
- CMS allows auxiliary personnel to provide RPM services under the supervision of the billing provider.[2]
- Thus, pharmacists can collaborate with those considered qualified healthcare professionals to promote healthcare access via RPM.[5]
What RPM services are pharmacists allowed to provide?
- Because auxiliary personnel must only be under the “general supervision” of the qualified healthcare professional, pharmacists can perform RPM services such as data monitoring, patient education and communication, and intervention.[7]
- An example of the provision of RPM services[6]:
- Qualified health professional (QHP who is a physician or non-physician provider eligible to bill Medicare for RPM services) identifies an eligible patient
- QHP fills out form referring patient to RPM program
- Form is faxed to pharmacy
- Pharmacy adds patient to their RPM program and explains program details
- Pharmacy coordinates delivery date for device
- Device is ordered
- Device is linked to the patient profile via serial number
- Device is delivered to the patient via pharmacy delivery
- Pharmacy educates patient on the appropriate use of the device as well as methods to obtain more accurate readings
- Pharmacy monitors daily readings received
- Reporting of readings is escalated as defined via protocol with QHP.
- QHP is contacted regarding readings when appropriate.
How can a pharmacist identify and partner with a QHP?
- Pharmacists can create collaborative contracts with qualified healthcare professionals, operating as contracted employees to provide RPM services.[6]
- Pharmacists can also join agencies and consulting firms that provide these services to physicians.[8]
Billing for RPM
Who Can Bill Medicare for RPM?
- Only practitioners (including physicians, nurse practitioners, or physician assistants) that are allowed to bill Medicare for Evaluation/Management (E/M) services can bill for RPM.[3]
Billing Limitations
- RPM does not include diagnostic tests.[3]
- RPM cannot be billed via an Independent Diagnostic Testing Facility.[3]
- Medicare requires that a patient-physician relationship is established for billing.[2]
- Medicare requires that the device collect RPM data a minimum of 16 days out of 30 days.[2]
Basic RPM Billing Codes
- Medicare uses the term “remote physiologic monitoring” in their coding and billing language. These billing codes describe non-face-to-face monitoring and analysis of physiologic factors used to understand a patient’s health status.[4]
- Initial Set-up and Continued Monitoring; Supplies
- CPT® 99453:
- Remote monitoring of physiologic parameter(s) (e.g., weight, blood pressure, pulse oximetry, respiratory flow rate), initial set-up and patient education on use of equipment. (Initial set-up and patient education of monitoring equipment)[5]
- All auxiliary personnel (including clinical staff and non-clinical) may provide education to patients on RPM services and set up of the device under CPT® code 99453.[4]
- CPT® code 99453 can be billed only once per episode of care which “begin[s] when the remote physiologic monitoring service is initiated and ends with attainment of targeted treatment goals’’.[3]
- CPT® 99454:
- Device(s) supply with daily recording(s) or programmed alert(s) transmission, each 30 days. (Initial collection, transmission, and report/summary services to the clinician managing the patient)[5]
- Is valued to include the medical device or devices supplied to the patient and the programming of the medical device for repeated monitoring.[4]
- CPT® 99453:
- Collecting and Analyzing Physiologic Data
- CPT® 99091
- Collection 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 of time, each 30 days)[5]
- The valuation for CPT® code 99091 includes a total time of 40 minutes of physician or NPP work, broken down as follows:
- 5 minutes of preservice work (for example, chart review)
- 30 minutes of intra-service work (for example, data analysis and interpretation, report based upon the physiologic data, as well as a possible phone call to the patient)
- 5 minutes of post-service work (that is, chart documentation).[4]
- CPT® 99091
- Management Services (First 20 Minutes/Each Additional 20 Minutes)
- CPT® 99457
- Remote 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[5]
- After analyzing and interpreting remotely collected physiologic data, the data is used to develop a treatment plan and then manage the plan until the targeted goals of the treatment plan are attained.[4]
- CPT® 99458
- Each additional 20 minutes (List separately in addition to code for primary procedure)[5]
- For Both CPT® 99457 and CPT® 99458
- Services are typically provided remotely using communications technologies that allow interactive communication.[4]
- Interactive communication, involves, a real-time synchronous, two-way audio interaction that is capable of being enhanced with video or other kinds of data transmission; as well as, time engaged in non-face-to-face care management services during calendar year.[4]
- These are designated as care management services and as such can be provided by clinical staff under the general supervision of the physician or NPP.[4]
- CPT® 99457
- To determine the dollar amounts paid by Medicare in your specific area you can input these CPT codes into the Physician Fee Schedule Search available at: https://www.cms.gov/medicare/physician-fee-schedule/search/overview
- Additional Coverage Requirements
- Advance patient consent: Practitioners must obtain advance consent for the service and document in the patient’s record.[5]
- 30-day reporting period: Billing limited to once in a 30-day period.[5]
- Use with other services: Billing is permitted for the same service period as chronic care management (CCM) (CPT® codes 99487–99490), transitional care management (TCM) (CPT® codes 99495–99496), and behavioral health integration (BHI) (CPT® codes 99484, 99492–99494).[5]
- CPT® codes 99457 and 99091 may not be billed together for same billing period and beneficiary.[5]
Paula Belle (BS Pharmacy, RPh) has been the Clinical Programs Coordinator for Morris & Dickson since 2016. Prior to joining M&D, Paula held the positions of Clinical Pharmacist with Pharmacea Services and PharmMD/Adhere Health, as well as Market Pharmacist, Store Pharmacy Manager and District Pharmacy Supervisor with Walgreens. She holds a BS in Pharmacy from the University of Louisiana at Monroe, as well as Immunization and MTM Certifications from the American Pharmacists Association (APhA).
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Sources
- Centers for Disease Control and Prevention. Telehealth Interventions to Improve Chronic Disease | cdc.gov. 2022 2022-03-16T03:55:46Z; Available from: https://www.cdc.gov/dhdsp/pubs/telehealth.htm.
- Health Resources and Services Administration. Leveraging Remote Patient Monitoring in Your Practice. 2022; Available from: https://th-site-downloads.s3.us-east-2.amazonaws.com/Leveraging+Remote+Patient+Monitoring+In+Your+Practice.pdf.
- Health Resources and Services Administration. Telehealth and Remote Patient Monitoring. 2022; Available from: https://telehealth.hhs.gov/providers/preparing-patients-for-telehealth/telehealth-and-remote-patient-monitoring/.
- Association of American Medical Colleges. AAMC Regulatory Resource:2021 Medicare Coverage of Remote Physiological Monitoring. 2021; Available from: https://www.aamc.org/media/55306/download.
- American Medical Association. Remote Patient Monitoring Playbook. 2022; Available from: https://www.ama-assn.org/system/files/ama-remote-patient-monitoring-playbook.pdf.
- Abubakar, A. and J. Sinclair, The Emerging Role of Community Pharmacists in Remote Patient Monitoring Services. Pharmacy (Basel), 2020. 8(3).
- Validic. What CMS’s Latest Proposed Rule Means for RPM | Validic. 2022; Available from: https://validic.com/what-cms-latest-proposed-rule-means-for-rpm/.
- Consulting, P.R. About Us: PCS Rx Consulting. 2022; Available from: https://pcsrxconsulting.com/about-1/.
- Image 2: by gpointstudio on Freepik.com
