AMA Considering Significant Extension of Remote Patient Monitoring Code Coverage

The American Medical Association (AMA) has unveiled the proposed agenda for its second quarter 2024 CPT Editorial Panel meeting in May, showcasing a potential expansion of Remote Patient Monitoring (RPM) and Remote Therapeutic Monitoring (RTM) CPT codes. These changes aim to bring about a positive transformation in the landscape of healthcare.

Exploring Potential RPM and RTM Enhancements:

The AMA is actively considering several key actions related to RPM and RTM, seeking to make these codes more comprehensive and user-friendly as described below:

  1. Potential introduction of a new RPM Device Supply Code: This proposed code would cover 2-15 calendar days of collected and transmitted data. Simultaneously, AMA plans to discuss revisions to the existing CPT 99454 to encompass 16-30 days. Together this would allow for two billable encounters for a month’s worth of device data allowing providers additional flexibility.

  2. Adjusting CPT 99457 Time Requirements: The revision of CPT 99457 is on the agenda, with a proposal to include 11-20 minutes for interactive communication. This change aims to reduce the time clinical staff must spend engaging with a patient/caregiver during the month for 99457 to be reportable, down from the current requirement of at least 20 minutes.

  3. Streamlining Interactive Communication for CPT 99458: AMA is considering a revision to CPT 99458 to cover each additional 10 minutes of interactive communication. This adjustment aims to reduce the required additional time for 99458 to be reportable, which currently stands at an additional 20 minutes.

  4. Adding Multiple RTM Codes: The AMA contemplates introducing three new RTM codes covering respiratory, musculoskeletal, and cognitive behavioral therapy for 2-15 calendar days.

  5. Revising CPT 98980: A proposal to include 11-20 minutes of service in CPT 98980 is under consideration. This change, akin to the revision in the existing 99457 RPM code, aims to reduce the necessary time for interactive communication during the month for 98980 to be reportable. If approved, AMA would further revise the 20-minute time component for CPT 98981.

Medicare Implementation Outlook:

While Medicare is not obligated to align with AMA's CPT code revisions, history suggests that the federal agency often adopts such changes. Private payers and health plans may choose to follow suit, further solidifying the impact of these amendments. If approved, it is anticipated that the coverage changes would not likely take effect until 2025.

Navigating Potential Course Reversals:

AMA's consideration of a full redesign of RPM CPT codes during its first quarter 2024 CPT Editorial Panel meeting took an unexpected turn with the withdrawal of the RPM code redesign application. This move seems strategic, allowing AMA to revisit and refine the proposed changes, as evident in the latest proposal slated for discussion in May. That being said, it is fully possible for them to rescind these changes based on the editorial meeting.

Implications for RPM and RTM Programs:

Should the proposed changes be implemented, and Medicare adopts them, providers in the RPM and RTM space will need to adapt their coding and billing practices. This holds true for private payers and health plans aligning with AMA's coding rules. Providers utilizing remote care management technology like the Mozzaz Platform can rest assured knowing that we will make necessary adjustments based on the evolving rules, to maintain compliant coding and billing as changes are made.

Furthermore, RPM and RTM providers should prepare for coding and billing scenarios involving services spanning 2-15 days and interactive communication sessions lasting at least 11 minutes, with additional 10-minute blocks beyond the initial 20 minutes. Embracing these new coding and billing opportunities may potentially enhance the financial value and performance of remote care management programs.

Engaging in the Dialogue:

For those interested in participating in the conversation or attending the meeting, here are the steps to follow:

  1. Registration for the Meeting: To register for the meeting, visit the registration page and click "Register now."

  2. Submitting Comments: To provide input, individuals must be identified as an "interested party." Submit your request through the "Interested Party Portal." Interested parties may have the opportunity to comment live during the meeting.

Disclaimer:

Reimbursement information provided by Mozzaz Corporation is gathered from third-party sources and is subject to change without notice as a result of complex and frequently changing laws, regulations, rules, and policies. This information is presented for illustrative purposes only and does not constitute reimbursement or legal advice.

Mozzaz Corporation recommends that you consult with your payers, reimbursement specialists, and/or legal counsel regarding coding, coverage, and reimbursement matters.

The coding options listed here are commonly used codes and are not intended to be an all-inclusive list. We recommend consulting your relevant manuals for appropriate coding options.

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