Remote Patient Monitoring: Contract Structures, Medicare Coverage, and Regulatory Compliance

Description

The Medicare Physician Fee Schedule 2021 Final Rule and subsequent guidance revised Medicare payment policies for remote physiologic monitoring. RPM can be provided "incident to" under general supervision, thereby making it less burdensome for providers to furnish RPM services. Medicare regulations define an "incident to" service as one performed under the supervision of and billed to Medicare by a qualified healthcare professional.

The Medicare Physician Fee Schedule 2022 Final Rule expands Medicare RPM payment codes to include remote therapeutic monitoring (RTM), in addition to previously covered remote physiologic monitoring codes. Those utilizing RPM must ensure they comply with licensure, scope of practice, and other requirements to be eligible for reimbursement.

Further, patient monitoring has historically been set up in healthcare facilities, while RPM and the associated monitoring equipment are deployed in the patient's home. This difference presents risks, including to data privacy and security. Among other issues, wireless networks, platforms, and devices are susceptible to being hacked, allowing access to sensitive health information, and many questions have arisen about considerations for patients' privacy and the security of their information.

As healthcare provider organizations seek to invest in and utilize RPM solutions, particularly as patients have become accustomed to remote care during the pandemic, they should consider the risks and compliance challenges to RPM and understand the reimbursement landscape.

Listen as our authoritative panel of healthcare attorneys examines reimbursement and how the Medicare Physician Fee Schedule, as well as other changes, impact the landscape for RPM. The panel will also address the challenges of RPM, such as privacy and security, as well as compliance considerations.