On March 14, the Centers for Medicare and Medicaid Services (CMS) released a technical correction to the 2019 Physician Fee Schedule Rule, offering the financial structure for both physicians and licensed medical professionals to be reimbursed for the use of remote monitoring. This correction signals a large step forward for CMS in its support for value-based care initiatives and delivery.

The technical correction clarified that CPT code 99457 may be billed as an “incident to” service – allowing qualified medical professionals, under direct supervision, to receive reimbursement for the delivery of remote monitoring services covered under CPT code 99457, as opposed to the reimbursement being available for physicians exclusively.

  • Under the 2019 Physician Fee Schedule Rule, three new CPT codes were released providing reimbursement for remote monitoring, including code 99457, which allowed providers to bill for “remote physiologic monitoring treatment management services.”

  • Discrepancies in the Rule resulted in a technical correction being released by CMS on March 14, clarifying that the code can indeed be billed “incident to” by licensed medical professionals under direct supervision of a physician.

  • This clarification opens doors for broader delivery of remote monitoring services by care teams, allowing physicians to work at the top of their licenses and for care teams to deliver care more efficiently.

99457, the CPT code which reimburses for the delivery of 20 minutes or more of “remote physiologic monitoring treatment management services” per month, was of critical importance during its release in the 2019 Physician Fee Schedule Rule. The code, along with two other new codes to support remote monitoring, offered a financial support structure to incentivize the provision and prioritization of remote patient monitoring (RPM) programs for patients managing multiple chronic conditions.

However, upon the release of the 2019 Final Rule in November 2018, CMS stated that CPT code 99457 “cannot be furnished by auxiliary personnel incident to a practitioner’s professional services,” limiting the usage of the code exclusively to physicians. This was considered a limiting factor for its usage, as many remote monitoring programs are largely managed by other licensed health professionals that report to a physician.

This technical correction clarified that CPT code 99457 can indeed be billed by qualified medical professionals, replacing their original statement in the rule with, “we thank commenters and confirm that these services may be furnished by auxiliary personnel incident to a practitioner’s professional service.” As such, other qualified medical professionals, with “direct supervision” from the billing practitioner, may code for such services.

An “incident to” service is described by CMS as “services that are furnished incident to physician professional services in the physician’s office (whether located in a separate office suite or within an institution) or in a patient’s home.” “Incident to” services must be a part of the patient’s normal treatment and must be delivered by licensed medical professionals.

Unless otherwise stated, “incident to” services must be performed under “direct supervision” of the physician, meaning that the physician must be in the same building at the same time at which auxiliary personnel are delivering the service. In some cases, CMS has chosen instead to allow incident to billing under “general supervision,” stating that the services may be billed for without the physician’s presence in the same building as the medical professional delivering the service. This is not the case for code 99457.

This announcement opens many doors for the growth of remote monitoring programs. This clarification makes it clear that CMS supports a shift to value-based care, in which providers are able to provide more meaningful care while operating more efficiently. By billing CPT code 99457 “incident to,” nurses or licensed care managers can use remote monitoring services to triage patients, allowing them to focus on patients who need intervention or active care the most, and allowing patients who are successfully self-managing to continue to do so. In addition, it relieves physicians of the ownership of all facets of remote monitoring, and instead enables them to operate at the top of their license.

Most care programs today are set up to enable care managers, rather than physicians, to review these data. This is often the preferred structure of an RPM program to ensure a physician can operate at the top of his or her license. With clarification that the services can be billed “incident to,” these programs can be scaled across care teams – and can incentivize broader deployments across systems.

By removing full ownership of all aspects of an RPM program from the physician individually, it allows him or her to support more patients with remote care management programs aimed at better engaging patients in treatment programs, managing behavior and lifestyle changes, and improving clinical outcomes, particularly for those with complex or multiple chronic conditions.

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