June 11, 2018 – Close to 50 healthcare organizations and vendors are lobbying the Centers for Medicare & Medicaid Services to improve reimbursement opportunities for remote patient monitoring.

In a letter delivered this morning to CMS Administrator Seema Verma, the group called on CMS to modify and add Current Procedural Terminology (CPT) codes that would enable Medicare reimbursement of mobile health programs that collect patient-generated health data in the home.

The group – led by ACT | The App Association – noted that CMS had taken a step in the right direction with the 2018 Physician Fee Schedule by unbundling CPT 99091 (“physician/healthcare professional collection and interpretation of physiologic data stored/transmitted by patient/caregiver”). The action separated the code from more restrictive telehealth guidelines and enables, with “several limitations,” providers to be reimbursed for collecting patient-generated health data through RPM platforms to monitor patients at home.

In the letter, the group is urging CMS to keep the unbundled code active, as well as “release and study related claims data that will yield important and unique insights on how these services are being employed.”

At the same time that CMS unbundled 99091, the American Medical Association’s CPT Editorial Panel approved three new codes that focus on RPM. The AMA has the sole authority to create CPT codes, though CMS doesn’t have to approve reimbursement for them.

The codes created by the AMA panel are:

• 990X0: Remote monitoring of physiologic parameter(s) (eg, weight, blood pressure, pulse oximetry, respiratory flow rate), initial; set-up and patient education on use of equipment;
• 990X1: device(s) supply with daily recording(s) or programmed alert(s) transmission, each 30 days; and
• 994X9: Remote physiologic monitoring treatment management services, 20 minutes or more of clinical staff/physician/other qualified healthcare professional time in a calendar month requiring interactive communication with the patient/caregiver during the month.

“While CMS has taken this commendable step forward in unbundling CPT 99091, we believe CMS must continue the commitment carefully articulated in the 2018 PFS Final Rule: to consider new digital health CPT codes created by the American Medical Association CPT Editorial Panel,” the letter states. “We stand in agreement with CMS that RM are paid under the same conditions as in-person physician services and can be a significant part of ongoing medical care.”

The letter further noted that the new codes were carefully vetted by the independent CPT Editorial Panel, which worked with the AMA’s Digital Medical Payment Advisory Group (DMPAG).

“It is our understanding that the AMA’s RVS Update Committee’s (RUC) undertook a valuation of these codes to which CMS has access,” the letter continued. “We urge CMS to cover, price and pay those new CPT codes utilizing the RUC information. There is an existing body of evidence demonstrating that these services will increase value and improve patient health outcomes, particularly for patients with multiple co-morbidities, chronic conditions, and those facing access barriers due to geography, limited mobility (and) medical fragility.”

The letter supports a growing body of evidence that RPM programs that enable providers to keep track of patients at home will reduce hospitalizations, avoid health emergencies that lead to more expensive care, improve patient engagement and care management and boost clinical outcomes.

Among those signing the letter are the American Heart Association, American Medical Association, American Telemedicine Association, College of Healthcare Information Management Executives (CHIME), Healthcare Information and Management Systems Society (HIMSS), InTouch Health, Mount Sinai Health System, Personal Connected Health Alliance (PCHA), Qualcomm Life, Proteus Digital Health, ResMed, the University of Pittsburgh Medical Center (UPMC), the University of Virginia Health System and Validic.

“As a community in support of connected health innovations in the Medicare system, we eagerly await the release of the next proposed and final Medicare Physician Fee Schedule,” the letter concluded, “and plan to provide further input to promote the use of remote monitoring innovations in the delivery of care.”