2024 Proposed Rule - Medicare Physician Fee Schedule - Five Key Impacts to Providers

On July 13, 2023, The Centers for Medicare and Medicaid Services (CMS) released the proposed 2024 Medicare Physician Fee Schedule. The proposed rule includes a few notable updates, and changes with the end of the PHE, for the remote physiologic monitoring and remote therapeutic monitoring codes. We’ve provided a summary of some updates, as well as the proposed reimbursement rates for 2024. 

Decrease in the Physician Conversion Factor

The proposed CY 2024 PFS conversion factor is $32.75, a decrease of $1.14 (or 3.34%) from the current CY 2023 conversion factor of $33.89.

Remote Monitoring for Established Patients

With the end of the PHE, RPM and RTM can now only be furnished to established patients. However, for patients that received remote patient monitoring services during the PHE, they are now considered established patients, and can continue to receive services. Medicare has stated that an established patient is one that has received face-to-face services within the last three years.

Use of RPM, RTM, in Conjunction With Other Care Management Services 

While CMS states they want to provide flexibility for practitioners in choosing the right services for a patient, they did clarify that RPM and RTM cannot both be billed together, along with other care management services. 

“Practitioners may bill RPM or RTM, but not both RPM and RTM, concurrently with the following care management services: CCM/TCM/BHI, PCM, and CPM. These various codes, which describe other care management services, may be billed with RPM or RTM, for the same patient, if the time or effort is not counted twice.”

Remote Physiologic Monitoring and Remote Therapeutic Monitoring May Not Be Billed for the Same Patient

CMS also wanted to clarify that RPM and RTM cannot be billed together for the same patient, but they also expressed that there may be scenarios where a patient receives both RPM and RTM services, but from different practitioners, and goes on to clarify the rule for this scenario. This section is confusing as they stated previously RPM and RTM cannot be billed concurrently for a patient, so hopefully this is clarified in the final rule. 

“We propose to clarify that RPM and RTM may not be billed together, so that no time is counted twice by billing for concurrent RPM and RTM services. In instances where the same patient receives RPM and RTM services, there may be multiple devices used for monitoring, and in these cases, we will to apply our existing rules, which we finalized when establishing the RPM code family, meaning that 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; and that the services must be reasonable and necessary (85 FR 84544 through 84545).”

16 Days of Data Collection Requirement Reinstated 

​​During the PHE, there was an exception to the data collection requirements of 16 unique days of readings. The requirement was dropped to a minimum of 7 days of data over a 30 day period for patients with COVID-19 or suspected COVID-19. However, with the end of the PHE, CMS has reinstated the 16 day data requirement stating, “Monitoring must occur over at least 16 days of a 30-day period. We are proposing to clarify that the data collection minimums apply to existing RPM and RTM code families for CY 2024.”

CMS went on to provide a list of codes that require no fewer than 16 days of data;

• 98976
• 98977
• 98978
• 98980
• 98981

It has previously been stated that RPM codes, 99453 and 99454, have the same requirement of no less than 16 days of data in a 30 day period for billing. 

What is new in this proposed rule, is that the RTM treatment management service codes, 98980 and 98981, are listed as needing to meet the 16 day data requirement, and not just the patient education set-up and device supply / data transmission codes. This could be troubling news for the RPM treatment management service codes, as this is not currently a requirement for 99457/99458. 

RPM and RTM Reimbursement for FQHCs and RHCs

CMS proposes that FQHCs and RHCs can furnish RPM / RTM services and can bill using G0511. The proposed amount would come to $78.92. 

“RHCs and FQHCs have inquired about receiving a separate payment for RTM and RPM services. They have stated that CMS should expand HCPCS code G0511 to include RPM treatment management services to provide Medicare beneficiaries in rural and underserved areas access to these services or establish G-codes to reimburse RHCs and FQHCs for RPM set-up and patient education on use of equipment (CPT code 99453) and monthly data transmission (CPT code 99554) and do not believe that these services are captured in the RHC AIR or FQHC PPS and as such are impeding access to these services.”

“Therefore, we propose that RHCs and FQHCs that furnish RPM and RTM services would be able to bill these services using HCPCS code G0511, either alone or with other payable services on an RHC or FQHC claim for dates of service on or after January 1, 2024.”

2024 Proposed RPM Rates

For further information on the RPM codes and requirements, download our 2023 RPM Reimbursement Guide, here. 

Additional Resources

2024 MPFS Proposed Rule Fact Sheet - https://www.cms.gov/newsroom/fact-sheets/calendar-year-cy-2024-medicare-physician-fee-schedule-proposed-rule 

2024 MPFS Proposed Rule - https://www.cms.gov/medicare/medicare-fee-service-payment/physicianfeesched/pfs-federal-regulation-notices/cms-1784-p