Overview

Already effective as of January 1, 2018, the unbundling of CPT code 99091 by the Centers for Medicare and Medicaid Services (CMS) means that eligible practitioners can bill to receive separate reimbursement “for time spent on collection and interpretation of health data that is generated by a patient remotely, digitally stored and transmitted to the provider, at a minimum of 30 minutes of time.”

With Mnemo, care providers can implement a remote patient monitoring system in minutes.

Before 2018, CMS rules mandated that certain remote care tasks could not be billed for the same patient during the same service period in conjunction with many of the treatments that commonly (and increasingly) utilize RPM services — specifically:

CPT codes 99487, 99489, and 99490, covering Chronic Care Management (CCM), including diabetes, hypertension, cardiovascular disease, and chronic obstructive pulmonary disease (COPD), among others CPT codes 99495 and 99496, covering Transitional Care Management (TCM), or services involving the period of care in which a patient is discharged from a hospital, rehab, nursing or similar facility to a home or assisted living setting CPT codes 99492, 99493, 99494, and 99484, covering General Behavioral Health Integration (BHI) services and a psychiatric collaborative care model (CoCM), including psychosocial assessment and preventive care recommendations and oversight of patient self-management/medications With the new CPT coding rules in place, however, remote care services that fall under CPT code 99091 can now be billed once per patient during the same 30-day service period as any of the above listed codes, significantly expanding the scope of Medicare reimbursement for remote treatment.

What providers should know prior to implementing remote monitoring:

Of course, as with any CPT coding procedure, there are still a series of carefully-defined requirements that must be met. The code is payable in both facility and non-facility settings; however, to ensure an eligible transaction, healthcare providers must first: Hold a face-to-face consultation with patients who are new (or who have not been seen within one year of the implementation of the remote care services) Obtain advanced beneficiary consent for the services, and document this in the patient’s electronic medical record (EMR) To remain eligible for reimbursement under CPT code 99091, the provider must also: Include the time spent assessing, reviewing and/or interpreting the data in the billing code Include time spent communicating with the patient (and family caregiver, if applicable), along with the details of the conversation, in the billing code Make use of digital tools “in such a way that allows them to provide ongoing guidance and assessments for patients outside of the in-office visit,” including “the collection and use of” patient-generated health data (PGHD) (via the C&M blog) Make use of platforms and devices that work as part of an “active feedback loop,” providing data in real time (or near-real time) to the care team as well as offering patients automatic and ongoing one-way guidance About that last point: It’s important to note that the CMS considers “passive platforms or devices” that collect but do not transmit PGHD as ineligible for reimbursement under the RPM code.

M-HEALTH
Mnemo collects symptom data via patients’ mobile phones. It then uses predictive models to identify who is at risk of descending into an exasperated condition. By promptly calling in the riskiest patients to their care provider for check-up, Mnemo can reduce costly outcomes such as ambulance rides and hospital re-admissions. Patient outcomes are improved, insurer costs are reduced.