The Centers for Medicare & Medicaid Services (CMS) have proposed changes to the Medicare Physician Fee Schedule for the calendar year 2024. While these changes are generally seen as being minor, they could still have an impact.
Notable Changes affecting Remote Patient Monitoring
Among the most notable of these changes is the allowance of payment to FQHCs and rural health clinics (RHCs) and the expansion of the RTM frameworks into behavioral health—both of which could help improve access to care in underserved communities. Additionally, the unbundling of RPM/RTM from other surgical global payments is a win for postoperative complications reduction market programs and companies.
In addition, CMS has proposed new CPT codes to be added to the Medicare Physician Fee Schedule in 2024. These include code for remote patient monitoring (RPM), which will allow physicians to receive reimbursement for 24/7 RPM services and code for reporting moderate sedation services provided during certain procedures. The changes are intended to encourage providers to use these technologies more widely.
Also, CMS is proposing an increase in the conversion factor from $36.09 to $37.89 starting in calendar year 2024, a move that would help keep up with inflation and ensure health care practitioners’ incomes remain stable.
The 16-Day Requirement
This 16 days thing is an arbitrary number that was created as a part of the code creation process. The 16 days each 30 days (essentially every other day) is clinically arbitrary and serves to prevent reimbursement in many cases where patients may only transmit 8 days or 6 days. Either a sliding scale of value (50% of reimbursement for 8 days) or a reduction to around 8 days (twice a week) per month would likely be equally as effective as an alternative to this rule—it would cost more money, but we really should focus on the ROI from an investment in these types of proactive care programs and not the comparatively minimal costs of ensuring they have the cash flow to run them. This is not a surprising reaffirmation and should not come as a shock to people who have been compliant.
Concurrent Billing with other Code Families (e.g., Chronic Care Management, Principle Care Management)
This was established a few years ago and is a big win for the connected care space. RPM/RTM and CCM services are highly complementary and provide sufficient funding to support programs in becoming more proactive in pursuit of better patient outcomes from high-impact chronic conditions. With combination programs, there is enough reimbursement to build our robust, high-touch care processes which are most effective when combined with RPM data collection.
Allowing Reimbursement to Rural Health Clinics and FQHCs
CMS proposes allowing federally-qualified health centers (FQHCs) and rural health clinics to bill for RPM/RTM services under a similar framework to chronic care management services which are already allowed. This makes sense. FQHCs often care for patient populations with hypertension, diabetes, and other chronic conditions at high rates so it makes sense to bring these technologies with proven outcomes into those settings. There have also been some bad rumors floating around the policy circles about how RPM can “exacerbate disparities”—which is just a massive logical fallacy and a failure to understand the evidence, but this is a step towards ensuring equitable access to these care models and technologies.
Overall, the proposed changes to the Medicare Physician Fee Schedule for 2024 are largely seen as minor but could still have a significant impact on patient access and care. By allowing FQHCs and RHCs to bill for RPM/RTM services, CMS is helping improve care in underserved communities while also incentivizing providers to use these technologies more widely.