CMS Initial 2024 Medicare Physician Fee Schedule Changes for Remote Patient Monitoring Services

On July 13, 2023, The Centers for Medicare and Medicaid Services (CMS) released its initial 2024 Medicare Physician Fee Schedule (MPFS). The new schedule includes additional extensions of telehealth flexibilities as well as several other implications for remote physiologic monitoring and remote therapeutic monitoring services. We refer to these services jointly as “remote monitoring” throughout this post.

Remote Monitoring for Established Patients Only

In the initial MPFS for 2024, remote patient monitoring services providers are reminded that the end of the public health emergency (PHE), earlier this year, eliminated the waiver that temporarily allowed new patients to receive remote patient monitoring services. Once again, under the initial MPFS remote patient monitoring services may be provided “only to an established patient.” Fortunately, patients who first received remote monitoring services during the PHE when this requirement was temporarily waived are now considered “established patients” under the rule.

The “16 Days of Data” Requirement Persists for 2024

Despite stakeholder opposition, the initial MPFS for 2024 continues to include that remote patient monitoring “must occur over at least 16 days of a 30-day period.” As pointed out by Nixon Gwilt Law in their blog post, “Changes for Remote Monitoring in the 2024 Proposed Medicare Physician Fee Schedule: What Providers and RTM/RPM companies need to know,” the wording in the rule has been modified slightly from “data transmission” to “data monitoring.” In addition, this data monitoring requirement is extended for 2024 to include remote therapeutic monitoring services CPT codes (such as CPT Codes 98980 and 98981).

Remote Monitoring Services May Now Be Billed Concurrently with Another Virtual Care Management Service

In the initial MPFS for 2024, a remote physiologic monitoring or remote therapeutic monitoring service, not both, may be billed concurrently with one of the following virtual care management services as long as there is no double counting of services or time treated:

• • Chronic care management
  • Transitional care management
  • Behavioral health integration
  • Principal care management
  • Chronic pain management

Remote Monitoring Services May Not Be Billed for the Same Patient

The initial MPFS for 2024 reiterates that remote physiologic monitoring and remote therapeutic monitoring services may not be billed together. The rule states that this is designed to ensure that “no time is counted twice by billing for concurrent” remote physiologic monitoring and remote therapeutic monitoring services.

The proposed rule goes on to say that in cases where the same patient receives both remote physiologic monitoring and remote therapeutic monitoring services, “there may be multiple devices used for monitoring” and these “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.”

The Nixon Gwilt Law blog post, mentioned above, outlines other key takeaways from the initial MPFS for 2024 related to remote patient monitoring services:

There is a 60-day public comment period on this proposed rule. In the proposed rule, CMS issues a request for information from stakeholders to better understand “the opportunities and challenges related to our coverage and payment policies” and how remote patient monitoring services are used in clinical practice. All interested parties, including providers, are encouraged to submit comments about the proposed changes to CMS to be considered in the development of the final rule.

The 60-day comment period closes on September 11, 2023 and comments can be submitted at Regulations.gov. CMS asks that any comments related to this rule refer to code CMS-1784-P. For further information about the fee schedule, you can read the press release from CMS or the associated fact sheet.

Additional Resources

Learn more about how XiFin revenue cycle management solutions and services can help medical device and remote patient monitoring companies improve commercialization as well as ongoing operational and financial results here.

Read the Nixon Gwilt Law blog post, “Changes for Remote Monitoring in the 2024 Proposed Medicare Physician Fee Schedule: What Providers and RTM/RPM companies need to know,” here.