2021 Remote Physiologic Monitoring Codes - Notable Updates

The 2021 Medicare Physician Fee Schedule made several updates and clarifications relating to the remote patient monitoring codes. We’ve included some notable policy and payment updates below.

Time Requirements and Interactive Communication
99457 / 99458 - CMS clarified in the final rule that time spent towards furnishing care management services / data interpretation and reviewing readings can be allocated towards the 20 minute time requirement to bill for 99457 and 99458. An “interactive communication” is still required as part of the 20 minutes, and CMS clarified that interactive communication “is a conversation that occurs in real-time and includes synchronous, two-way interactions that can be enhanced with video or other kinds of data as described by HCPCS code G2012.”

Established Patients
During the COVID-19 PHE remote monitoring services can be ordered for new patients, however, after the COVID-19 PHE ends, there must be an established patient-provider relationship for RPM services to be furnished. This would require a face-to-face visit with a patient within the prior year. Some states do allow patient-provider relationships to be established via telehealth.

Automatic Data Capture
CMS clarified that physiologic data must be electronically (i.e., automatically) collected and transmitted rather than self-reported / manually entered by the patient. This requires the use of “connected” devices, such as Bluetooth, wifi, and cellular enabled devices, to capture measurement readings and transmit them to the cloud for review.

Patient Onboarding / Training / Supply of Equipment
99453 / 99454 - Auxiliary personnel (including clinical and non-clinical staff, as well as contracted employees) can provide services described by CPT codes 99453 and 99454 incident to the billing practitioner’s services and under their supervision.

Rural Health Clinics and Federally Qualified Health Centers
RHCs/ FQHCs are still not granted standalone reimbursement for remote patient monitoring, which is disappointing (and confusing) considering the fact that they can bill for Chronic Care Management “CCM”, another care management service.

2020 vs 2021 Payment Rate Comparison (National)

Additional Resources

Medicare Physician Fee Schedule for Calendar Year 2021 Fact Sheet -

https://www.cms.gov/newsroom/fact-sheets/final-policy-payment-and-quality-provisions-changes-medicare-physician-fee-schedule-calendar-year-1

Medicare Physician Fee Schedule for Calendar Year 2021 Final Rule -

https://www.federalregister.gov/documents/2020/12/28/2020-26815/medicare-program-cy-2021-payment-policies-under-the-physician-fee-schedule-and-other-changes-to-part

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