2022 Physician Fee Schedule Care Management Updates

2022 Physician Fee Schedule Care Management Updates

The 2022 Medicare Physician Fee Schedule Final Rule was published Nov 2, 2021, and it includes good news, and some bad news, for care providers furnishing care management services. 

Care management updates in the final rule include;

• Expanded codes and an increase in reimbursement for;
  • Chronic Care Management (CCM)
  • Complex Chronic Care Management (CCCM)
  • Principal Care Management (PCM)
• New reimbursement for Remote Therapeutic Monitoring (RTM)
• A small decrease in reimbursement for three of the four remote physiologic monitoring codes, and a larger decrease in reimbursement for one of the four, 99454, the data transmission and equipment code associated with remote physiologic monitoring. 

Remote Physiologic Monitoring 2022 Reimbursement Updates

There were not any changes to the remote physiologic monitoring codes in the Physician Fee Schedule Final Rule, other than a decrease in reimbursement. This is disappointing for remote monitoring technology developers, and care providers. For many care providers, reimbursement was a means to finally provide connected health technology and services to their patients. 

Reimbursement stays the same, regardless of how many devices are provided to a patient, or whether the patient is also provided with cellular or Internet connectivity to transmit data. These were challenges providers were already facining, and now it will be even more difficult to implement programs with a decrease in reimbursement, specifically a large decrease to the technical component, which provides reimbursement for the equipment and technology.  

Previously, the remote physiologic monitoring treatment management service codes, 99457 and 99458, reimbursed at a higher rate than the CCM codes. For 2022, the CCM codes now reimburse at a higher rate. It may make sense for providers currently providing 99457/99458 to look at switching to providing CCM services. While the CCM codes do have different requirements and patient inclusion criteria, it could be worth reviewing. 

For providers wanting to capture biometrics, they can still bill for the RPM technical component code (99454), but provide the CCM services, as opposed to the RPM treatment management service components (99457/99458). 

Remote Therapeutic Monitoring (e.g., respiratory system status, musculoskeletal system status, therapy adherence, therapy response)

CMS introduced five new remote therapeutic monitoring codes for 2022. The RTM family includes three PE-only codes and two codes that include professional work.

The codes provide exciting new opportunities to expand virtual care, with the ability to capture non-physiologic health data from patients, like medication adherence and therapy adherence. The new RTM codes closely resemble the existing Remote Physiologic Monitoring (RPM) codes. However, the RTM codes are general medicine codes which enable them to also be billed by healthcare providers who cannot bill for evaluation and management codes. This would enable therapists (PT, OT, SLP), psychologists, social workers, etc. to utilize these codes. 

Unlike RPM, the RTM codes are limited to two system use cases - musculoskeletal and respiratory systems. As these are general medicine codes, and not designated care management codes, a physician or non-physician practitioner billing for these services must provide direct supervision if clinical staff are furnishing services.

CMS also clarified in the proposed rule that non-physiologic data may include self reported data. This data is not required to be captured by an actual physical device, but can be captured through other means such as mobile apps, and web-based platforms, as long as they still meet the FDA definition of a medical device. 

Remote Therapeutic Monitoring Codes Reimbursement Rates

References

Rates listed are National Payment Amount, Non Facility Price.