2024 Medicare Physician Fee Schedule: Impact on Remote Physiologic Monitoring and Remote Therapeutic Monitoring Services

On November 2, the Centers for Medicare and Medicaid Services (CMS) released the 2024 Physician Fee Schedule, including new policies for remote physiologic monitoring (RPM) and remote therapeutic monitoring (RTM) services reimbursed under the Medicare program.

Below are the key takeaways RPM and RTM providers must know about the 2024 Final Rule.

1. Remote Physiologic Monitoring Requires an Established Patient Relationship

In the 2024 Final Rule, RPM, but not RTM, requires an established patient relationship. This means that any patients receiving RPM services after the end of the Public Health Emergency (PHE), which expired in May 2023, need to be established patients before receiving those services. Historically, to be considered an established patient for Medicare RPM purposes, a patient typically would undergo a new patient Evaluation and Management (E/M), or similar service, during which the billing practitioner collects relevant information about the patient and then establishes a treatment plan. During the Public Health Emergency (PHE), CMS waived the established patient requirement. Those patients who received remote monitoring services during the PHE but who did not undergo an initial new patient exam will be deemed “established patients” under CMS’ recent rule clarification.

RTM does not contain an “Established Patient” requirement (at this time). However, for RTM, CMS noted it expects the billing practitioner to establish a treatment plan before providing RTM services, which may include an initial interaction/evaluation with the patient.

2. Practitioners Are Not Required to Collect at Least 16 Days of Data Per 30-day Period for Treatment Management Codes

The 2024 Final Rule clarifies which remote monitoring codes require at least 16 days of data collection in a 30-day period, and which codes have no such requirement. RPM and RTM set-up and device codes (CPT codes 99453, 98976, 99454, 98977, and 98978) require at least 16 days of data collection. CMS confirmed that the 16-day requirement does not apply to treatment management codes 99457, 99458, 98980, and 98981.

3. Only One Practitioner Can Bill Medicare for RPM/RTM Services in Any Given 30-day Period

The 2024 Final Rule states that in a given 30-day period, only one practitioner can bill RPM (CPT codes 99453 and 99454) or RTM (CPT codes 98976, 98977, 98980, and 98981), and only when at least 16 days of data has been collected on at least one medical device. According to an analysis by Foley & Lardner LLP, CMS states that “even when multiple medical devices are provided to a patient, the services associated with all the medical devices can be billed by only one practitioner, only once per patient, per 30-day period and only when at least 16 days of data have been collected.”

That said, according to a blog on the 2024 Final Rule by Nixon Gwilt Law, practitioners are permitted to bill Medicare for RPM or RTM (but not both) concurrently with the code sets for Transitional Care Management (“TCM”), Chronic Care Management (“CCM”), Behavioral Health Integration (“BHI”), Principal Care Management (“PCM”), and Chronic Pain Management (“CPM”) services.

4. Billing Medicare for RPM or RTM Services During Global Service Periods

According to the Nixon Gwilt blog referenced above, the 2024 Final Rule allows practitioners to bill and receive separate payment for RPM or RTM during a global service period, “so long as the remote monitoring services are unrelated to the diagnosis for which the global service was performed” and “as long as the purpose of the remote monitoring addresses an episode of care that is separate and distinct from the episode of care for the global procedure.”

A global service or billing period is where a practitioner receives a lump payment covering the post-surgical follow-up services within the global period. Practitioners who perform global procedures and receive global payment cannot receive separate payments for RPM or RTM when the monitoring is directly related to the condition the global procedure addresses because the global billing payment received by the practitioner covers those post-surgical follow-up services.

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