RPM CCM AWV
RPM CCM AWV

Every year, at the end of the year, The Centers for Medicare & Medicaid Services (CMS) releases the Physician Fee Schedule Final Rule. It reflects updates and policy changes for Medicare payments.

In remote care, this means that existing streams of payment are affected due to either 1) the scrapping of old codes, 2) modification of existing codes, 3) the introduction of new rules, and/or 4) the introduction of new codes.

CMS has finalized the proposed rule for the new year. This article presents all the changes for 2023. 

Let’s first look at streams of remote care that have not undergone any changes. There may have been many proposed modifications for these revenue streams for physicians, but CMS did not accept them, and hence they remain unchanged from 2022.

Medical Billing Options That Have No New Changes

For remote patient monitoring, principal care management, and transitional care management, please refer to the following pages mentioned below on Humhealth’s website. All of the information remains accurate without any need for new changes.

Remote Patient Monitoring (RPM)

Principal Care Management (PCM)

Transitional Care Management (TCM)

Changes in Remote Care for 2023

changes in remote care for 2023

Behavioral Health Integration and Remote Therapeutic Monitoring have all undergone changes, either in the form of new code additions, or rule modifications.  Each is expanded on in the following sections.

Chronic Pain Management (CPM)

CMS finalized two new HCPCS codes, G3002 and G3003 for CY 2023. 

G3002: Chronic pain management and treatment, monthly bundle including: diagnosis, assessment and monitoring, administration of a validated pain rating scale or tool, the development, implementation, revision, and/or maintenance of a person-centred care plan.

This person-centred care plan includes strengths, goals, clinical needs, and desired outcomes; overall treatment management; facilitation and coordination of any necessary behavioral health treatment; medication management; pain and health literacy counselling; any necessary chronic pain-related crisis care; and ongoing communication and care coordination between relevant practitioners furnishing care, e.g. physical therapy and occupational therapy, complementary and integrative approaches, and community-based care, as appropriate.

Required initial face-to-face visit at least 30 minutes provided by a physician or other qualified health professional; first 30 minutes personally provided by physician or other qualified healthcare professional, per calendar month. (When using G3002, 30 minutes must be met or exceeded.)

G3003: (Each additional 15 minutes of chronic pain management and treatment by a physician or other qualified healthcare professional, per calendar month. (List separately in addition to code for G3002. When using G3003, 15 minutes must be met or exceeded.) A physician or other qualified health care professional may bill this code an unlimited number of times, as medically necessary, per month.

CMS is confident that the new HCPCS codes will increase the accuracy of payments for these services, encourage more healthcare professionals to accept Medicare beneficiaries with chronic pain into their practices, and motivate those who are already providing care to Medicare beneficiaries with chronic pain to take the time to support their patients in managing their condition as part of a dependable, encouraging, and long-lasting care partnership.

The following rules regarding G3002 and G3003 are worth noting:

  • The first time G3002 is invoiced, the practitioner needs to see the patient in person.
  • CMS is not placing restrictions on the kinds of physician specialties or qualified health professionals who can provide CPM services.
  • CMS is not limiting the types of physician specialties, or the types of qualified health professionals, who can furnish CPM services, as long as they can provide all of the service elements of HCPCS code G3002, including prescribing medication as necessary, within their scope of practise in the State in which the services are furnished.
  • With the exception of the first visit, where G3003 must be presented in person, these codes will not be restricted to any particular locations for services.
  • Depending on the clinical situation, any of the CPM in-person components found in HCPCS codes G3002 and G3003 may be provided via telehealth.

Behavioral Health Integration (BHI)

In order to account for monthly care integration, wherein the mental health services provided by a clinical psychologist or clinical social worker serve as the focal point of care integration, CMS finalized the creation of a new G code that describes general BHI performed by clinical psychologists or clinical social workers.

G0323: Care management services for behavioral health conditions, at least 20 minutes of clinical psychologist or clinical social worker time, per calendar month. These services include the following required elements: Initial assessment or follow-up monitoring, including the use of applicable validated rating scales; behavioral health care planning in relation to behavioral/psychiatric health problems, including revision for patients who are not progressing or whose status changes facilitating and coordinating treatment such as psychotherapy, coordination with and/or referral to physicians and practitioners who are authorized by Medicare law to prescribe medications and furnish E/M services, counselling and/or psychiatric consultation, and continuity of care with a designated member of the care team.

Remote Therapeutic Monitoring (RTM)

Any RTM service may be provided under general supervision standards, according to CMS, which focused its revisions on the levels of supervision necessary for clinical staff members working in an RTM program.

CMS does not try to correct its previously voiced concern that general supervision is not permissible for non-E/M services codes. While this change will benefit Medicare practitioners eligible to bill “incident to,” it may not override the existing “incident to” prohibition for services provided incident to a therapist.

Therefore, it is unclear how the policy change will benefit non-physician Qualified Health Care Practitioners like clinical psychologists and physical therapists.

By finalizing a new RTM device supply code for Cognitive Behavioral Therapy Monitoring, CPT code 989X6, CMS widened the window for additional RTM use cases.

However, CMS chose to let the various Medical Administrative Contractors (the “MACs”) decide whether or how to reimburse the code rather than establishing a national payment value for it.

The code reads as follows:

CPT code 989X6: Supply of Device for Cognitive Behavioral Therapy Monitoring (Remote therapeutic monitoring (e.g., respiratory system status, musculoskeletal system status, cognitive behavioral therapy, therapy adherence, therapy response); initial set-up and patient education on use of equipment, device(s) supply with scheduled (e.g., daily) recording(s) and/or programmed alert(s) transmission to monitor cognitive behavioral therapy, each 30 days)

Changes to Remote Care for the New Year

changes to remote care for the new year

With every passing year, CMS and physicians work collaboratively to make changes that 1) make it easy to be reimbursed, 2) provide the optimum care value to patients, and 3) provide an ideal experience for both patients and the care team. It’s important to remember however, that remote care is a relatively newer form of care, and thus there are reimbursement codes from past years that are still rising in adoption, or have not been fully embraced just yet.

So, in line with being aware of what changes the new year will bring, it’s also important to revisit old articles in the Humhealth blog that outline and address different aspects of remote care. Most of the codes mentioned and advice given are still relevant. It’s only the specific new changes that we have highlighted in this article.

References

https://www.cms.gov/newsroom/fact-sheets/calendar-year-cy-2023-medicare-physician-fee-schedule-final-rule

https://nixongwiltlaw.com/nlg-blog/2022/11/7/key-takeaways-for-remote-therapeutic-monitoring-in-the-final-2023-medicare-physician-fee-schedule-general-supervision-for-all-rtm

https://www.powerslaw.com/changes-to-telehealth-behavioral-health-integration-and-remote-monitoring-services-under-the-cy-2023-medicare-physician-fee-schedule-final-rule/

https://www.jdsupra.com/legalnews/medicare-remote-therapeutic-monitoring-7145379/

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