The urgency of the COVID-19 pandemic has illustrated how essential telehealth services are to ensuring quality and accessible care for patients. The regulatory landscape has not yet caught up to the industry’s rapidly evolving needs, but rules have been changing slowly but surely. In the past few years, the Centers for Medicare & Medicaid Services (CMS) along with private insurers have begun to reimburse for remote patient monitoring (RPM) along with other telehealth services. But the COVID-19 pandemic prompted regulators to rapidly increase reimbursement—and loosen policy related to telehealth services and RPM. While many of these regulatory changes are in place only for the duration of the COVID-19 pandemic, their increasing use and support indicates that many changes are here to stay.
RPM “uses digital technologies to collect medical and other forms of health data from individuals in one location and electronically transmit that information securely to healthcare providers in a different location for assessment and recommendations.”1 Improvements in reimbursement for RPM better enable connected health services to facilitate remote monitoring, care management, and coordination—to improve and make care more accessible for patients, particularly those in rural or underserved areas.
By enabling more continuous communication and a higher standard of care, RPM has the potential to dramatically improve healthcare outcomes for patients while cutting costs associated with hospital readmissions, poor follow-up care, and other challenges patients with both chronic and acute conditions face.
In the past, RPM was interpreted to refer to the collection of data from connected devices such as heart rate monitors or blood pressure cuffs. Recent clarifications broaden applicability to conditions that involve patient-reported data, such as medication side effects, pain, or mental conditions.
Reimbursement Changes for RPM Prior to COVID
CMS distinguishes between RPM and telehealth; for example, reimbursement is not limited by geography to rural or medically underserved areas, and these services have no “originating site” restriction (the patient can be at home). The recent addition of new reimbursement codes has created increasing distinctions between telehealth and RPM, with significantly less restrictive reimbursement requirements on the latter. Nonetheless, RPM reimbursement has traditionally lagged behind reimbursement for live video and store-and-forward technologies.
The past few years have seen a dramatic increase in possibilities of reimbursement for RPM. The 2018 Medicare Physician Fee Schedule created unbundled, standalone reimbursement for physicians and other qualified healthcare professionals who use RPM to improve quality of care for patients, and in 2019 and 2020, Medicare introduced additional codes that could be used for RPM reimbursement.
The 2020 Medicare Physician Fee Schedule (PFS) included several updates that modernize the ways in which hospitals and health systems can use RPM to better assist patients. The set of RPM codes, described as “remote monitoring of physiologic parameter(s) [e.g., weight, blood pressure, pulse oximetry, respiratory flow rate]…” serve as part of an ongoing effort to compensate providers for their use of technology and modernize billing practices.2 Changes that went into effect on January 1st of this year allow for “incident to” billing under general supervision, meaning that medical assistants can perform RPM services under physician supervision, but from a different location. These new RPM codes can be used for all Medicare patients with a chronic condition.
Changes to RPM as a Result of COVID
In light of the COVID-19 pandemic, a new rule issued by the HHS in response to the COVID-19 pandemic stated: “We believe that RPM services support the CDC’s goal of reducing human exposure to the novel coronavirus while also increasing access to care and improving patient outcomes.”3 This statement signified that regulators understood the value of telehealth and RPM as a powerful tool to maintain access to healthcare in the midst of a global pandemic, and was accompanied by various changes to RPM reimbursement and rules for the duration of the national emergency.
These changes include an expansion of RPM codes for Medicare; they can now be used not only for patients with chronic conditions, but also those with post-surgical or acute conditions—including COVID-19. This clarification, issued as part of the new rule issued by HHS, seems to extend beyond the national emergency. RPM can additionally be ordered by a provider for new patients without a pre-existing relationship for the interim, and consent to receive RPM services need only be obtained annually.4
Additional state-by-state regulatory changes have emerged in the past few months with regard to Medicaid reimbursement for RPM. As of February of this year, 23 states have some form of reimbursement for RPM in their Medicaid programs. Yet COVID-19 has prompted some states to move even more rapidly, and directly expand RPM reimbursement.
Maryland recently expanded its RPM codes and waived certain regulatory requirements, now covering all conditions capable of monitoring via RPM, Florida has expanded telehealth to include RPM modalities “for certain evaluation and management services provided during the state of emergency period,” and Kentucky issued a temporary code to bill remote evaluation services. Other states have loosened telehealth restrictions with less clarification as to how these changes would affect RPM, such as stating that all services that can be effectively provided through telehealth should be reimbursed.
While these changes to RPM reimbursement and regulation are temporary, there is evidence of broader support from lawmakers, providers, and payers for long-term changes beyond the pandemic. Twenty-nine senators sent a recent letter to Congressional leadership, advocating that recent shifts in telehealth regulations for the duration of the COVID-19 emergency be made permanent. RPM’s value to patients and providers alike in making high-quality care more accessible, as well as a friendlier regulatory landscape, indicate that RPM will play an increasingly outsize role in healthcare in the future.
References:
1. Center for Connected Health Policy: “State Telehealth Laws & Reimbursement Policies.”
2. Nixon Law Group: “Remote Patient Monitoring Reimbursement Overview.”
3. Department of Health and Human Services: “Medicare and Medicaid Programs; Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency.”
4. Department of Health and Human Services: “Medicare and Medicaid Programs, Basic Health Program, and Exchanges; Additional Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency and Delay of Certain Reporting Requirements for the Skilled Nursing Facility Quality Reporting Program.”
