CMS final rules for 2023 – expansion of RTM billing applications

The 2023 Centers for Medicare and Medicaid Services (CMS) Medicare Physician Fee Schedule (MPFS) final rules were just released, and the biggest takeaway is the continued growth of Remote Therapeutic Monitoring (RTM) with the expansion of billing to include/allow for general supervision billing. The other update to highlight  is new codes for Chronic Pain Management (CPM). There were only a few changes impacting digital health and remote patient monitoring for next year, but CMS clearly continues to support, grow and deepen the foundation for remote patient monitoring services.

Key 2023 CMS MPFS final rule updates

• Expansion of RTM to apply to general supervision
• Addition of Chronic Pain Management (CPM) with new codes

General supervision for RTM

When the 2023 draft recommendations were released in July, CMS had proposed numerous RTM codes which potentially made billing more expansive, but very complicated. In response to feedback during the review period, in the end, they did not adopt those codes and instead simply went with expansion to general supervision billing for all RTM services for the 2023 Final Rule. Adding, “General supervision does not require that the physician and clinical staff be in the same building at the same time as the RTM services are furnished. Rather, the billing provider may bill for services furnished by auxiliary clinical staff under the supervision, provided that the other requirements for “incident to” services are met.” Rather than create additional G codes, CMS simply refined the supervision requirements for RTM services under the existing codes. This is an exciting and important development that now allows the full clinical staff team to utilize RTM more efficiently and effectively, while improving patient care. Providers can focus on direct patient care, and clinical staff can support patients using the tools provided.

New codes for Chronic Pain Management and treatment services (CPM)

Also for 2023, CMS has added new HCPCS codes – G3002 and G3003 – valuation for Chronic Pain Management and Treatment Services (CPM) –  that will according to CMS, will allow more providers to welcome Medicare beneficiaries with chronic pain into their practices, and will encourage providers already treating Medicare patients who have chronic pain to spend time to help them manage their condition with a trusting, supportive and ongoing care partnership. The finalized codes include a bundle of services furnished within a 30-day period that are a starting point for holistic chronic pain care. They also provided some additional flexibility, such as the ability to report CPM and other visits on the same date and to report subsequent CPM services as many times as needed in a month.

The following are included in the CPM Code descriptor: diagnosis, assessment and monitoring; administration of a validated pain rating scale or tool; development, revision and/or maintenance of a person centered plan that 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 counseling; any necessary chronic pain related crisis care; and ongoing communication and coordination between relevant practitioners furnishing care, such as physical and occupational therapy, complementary and integrative care approaches, and community-based care, as appropriate.

Chronic Pain Management  (CPM):

• Code: G3002 - Valuation for chronic pain management and treatment  services – 30 minutes/month
• Code: G3002 - Valuation for chronic pain management and treatment  services – each additional 15 min/ month

Some key discussions that were on the table, remain unchanged for 2023.  These are likely changes for 2024.

Potential changes for 2024

• The 16-Day Requirement for Remote Therapeutic Monitoring
• Generic data code for Remote Therapeutic Monitoring

One example is the 16 days of data requirement for RTM codes 98975, 98976 and 98977. CMS will consider new CPT code requirements for <16 days of data collection in future years. Also, there was some hope for a generic RTM data code given the success of generic codes for other Remote Physiologic Monitoring (RPM)  and other remote patient monitoring services – but CMS did not do this for 2023 – and RTM still only covers data to monitor respiratory (98976) or musculoskeletal (98977) systems. With successful use of a generic data code for RPM services during the past four years, it remains hopeful that ultimately CMS will approve a generic RTM data code in the future.

Overall, CMS is trying to reduce the coding and billing complexity for RTM services, which increases the care delivery flexibility and promotes access to RTM services. It’s fair to assume that in future years, CMS will continue modification of the RTM and RPM code sets.

Each year CMS’ changes and additions continue to trend in a positive direction for remote patient management services – adding more and broader coverage each year. CMS is listening to requests and feedback from the remote patient monitoring community.

Why Medsien

In early 2022, Medsien launched the first – and only – RTM and pain management platform. Already delivering one of the most unique and advanced software and staffing hybrid remote care platforms in the industry, Medsien expanded its services to help specialty pain management practices start to integrate sophisticated, seamless and cost-effective remote monitoring into their workflows. Almost a year later, It remains the only comprehensive solution on the market specifically for pain management providers. With consistent, real-time, secure access to patients’ important non-physiological details, pain management specialists now can more easily understand patient health status and monitor behavioral health trends more closely. The latest code expansion for 2023, opens the door to even greater possibilities to help pain practices with Medsien’s RTM programs. This is a great time to add remote care management and monitoring services to your practice.