CMS final rule supports reimbursement for remote patient monitoring by FQHCs and RHCs.
Remote patient monitoring (RPM) has been an important care delivery model for patients in underserved communities with transportation or other barriers to care. Yet, until just recently, there has been little to no reimbursement for practices that serve these patients to sustain these valuable programs, which are making a positive impact on the outcomes of many patients.
That will change in 2024, according to the U.S. Centers for Medicare & Medicaid Services’ (CMS) Calendar Year (CY) 2024 Medicare Physician Fee Schedule Final Rule. For the first time, Federally Qualified Health Centers (FQHCs) and Rural Health Centers (RHCs) – the primary organizations bringing care to underserved markets and patients – have a tangible way to build and sustain their remote patient care programs. The rule enables FQHCs and RHCs to bill for RPM and remote therapeutic monitoring (RTM) in the general care management HCPCS code G0511. Having such a rule in place gives these health care providers more certainty about continuing existing programs and a pathway to expand remote management services to a wider array of patients and monitor more conditions.
Underserved communities face challenges in accessing care – whether it’s their ability to get to their doctor’s office for preventive care or sick visits, or their ability to pay for it. FQHCs and RHCs serve the patients in these communities – many of whom have multiple, comorbid chronic conditions.
However, there is a growing body of evidence that shows remote management of patients – particularly those with chronic conditions such as high blood pressure, diabetes, heart failure and asthma – offers a myriad of benefits. A recent KLAS Research report noted that more than one-third of health care organizations saw fewer readmissions when using RPM for chronic care management. Additionally, a recent study correlated RPM devices with improved patient outcomes.
FQHCs and RHCs have been able to gain greater insights into patients' well-being when extending services beyond traditional in-person visits. By enabling more regular monitoring of their conditions, these health care providers can help prevent complications between in-person visits. Data generated by RPM tools also enable providers to take proactive measures, such as adjusting medication, changing diet or altering activities, so patients can achieve better outcomes while minimizing health care costs for both patients and payers.
For too long, though, the ability of FQHCs and RHCs to offer and be reimbursed for RPM and RTM has been hampered by uncertainty. Experience during the COVID-19 pandemic showed the positive impact of incorporating these remote offerings into the care continuum, as grants funded for early RPM projects and specific disease management initiatives. However, those initial programs were limited in scope and duration, leaving providers to figure out how to continue them. At the time Medicare did not reimburse FQHCs and RHCs for RPM activity and Medicaid in select states often didn't cover RPM for FQHCs or had onerous restrictions that prevented more widespread use.
While waiting for Medicare to update proposed rules, FQHCs had to get creative to continue funding their RPM programs. Some incorporated them into chronic care management to support patients with multiple chronic conditions by providing non-face-to-face care coordination and management. Others used RPM data to add more in-person visits based on medical necessity, with payments for those visits helping support RPM programs. And yet others leveraged the data they collected under grant-supported RPM programs to show real-world positive outcomes and successful deployments, which bolstered the case for additional grant support to continue or enhance RPM offerings.
The Proposed 2024 Physician Fee Schedule, which was released in July, indicated that remote monitoring would be covered. But there were still several questions about how it would work. Finally, in early November, the CMS confirmed that beginning in 2024, the general management code HCPCS G0511, which already included other non-face-to-face services, like chronic care management (CCM) and behavioral health integration services, would be expanded to include FQHCs and RHCs reimbursement for RPM and RTM services.
In the final rule, the CMS addressed concerns that using the G0511 code for distinct services like CCM and RPM would not sufficiently account for the resources required to provide these individual services. It noted that G0511 could be billed for the same patient more than once per month, for all subcategory codes, as long as all the requirements were met. Additionally, because of the ability to bill G0511 multiple times, CMS adjusted the average reimbursement amount for this code from $77.94 in 2023 to $72.98 in the coming year.
With the actions on RPM taken by CMS, it's expected that many state Medicaid plans will follow suit. Currently, only about 34 state Medicaid programs provide RPM reimbursements, but this often does not include FQHCs. To stay abreast of changes, providers can check their state Medicaid policies on the Center for Connected Health Policy website.
While the number of those health care providers offering RPM is expected to reach about 76% by the beginning of 2024, it’s anticipated that with the changes in reimbursements, greater adoption of technology and expansion of existing programs, more than 70 million U.S. patients – 26.2% of the population – will benefit from some kind of RPM. This is good news for the more than 67 million people who rely on FQHCs and RHCs. The addition of more RPM and RTM offerings, as a result of CMS reimbursements, will provide underserved patients with more effective tools to manage chronic diseases proactively and minimize complications.
Lucienne Ide, MD, PhD, is founder and CEO of Rimidi, a digital health company that supports health care providers in the delivery of remote patient monitoring and chronic disease management with EHR-integrated software, services, and connected devices.