2024 CMS Update Spotlight: Expansion of RPM and RTM to FQHCs and RHCs

CMS continues to advance the ability of Remote Patient Monitoring (RPM) and Remote Therapeutic Monitoring (RTM) services to drive revenue and improve the patient care experience. 

 Key Takeaways:

• Significant Change: FQHCs and RHCs can now bill for RPM and RTM services
• The final 2024 payment rate for the general care management HCPCS code G0511 is $72.98 (National Average Reimbursement Rate). 

•  While a reduction from the 2023 rate, expansion improves access and reimbursement overall.

• Multiple billing allowed: CMS clarifies that G0511 can be billed multiple times for the same patient each month.
• Enables FQHCs and RHCs to increase scope and reach of services, increase revenue and improve patient outcomes.
• This expansion for patients improves access to healthcare for underserved populations in remote areas, supports early intervention of care management, improves patient outcomes and promotes health equity. 

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FQHCs and RHCs may now bill for RPM and RTM services 

As of January 1, 2024, RHCs and FQHCs are able to bill Medicare for RPM and RTM, using HCPCS code G0511. The RPM and RTM services must be medically reasonable and necessary, meet all the coding requirements, and not duplicate services already paid for under the general care management code for an episode of care in a given calendar month. Historically, FQHCs and RHCs were not authorized to separately bill for RPM and RTM services, and payment was made through an all-inclusive rate rather than separate reimbursement. This is an important and significant change.

Multiple monthly billing for G0511

RHCs and FQHCs may now bill HCPCS code G0511 multiple times in a calendar month for the same patient, when all requirements are met and resource costs are not counted more than once. This means that if a patient is enrolled in both Chronic Care Management (CCM) and RPM or RTM programs simultaneously, FQHCs and RHCs can legitimately bill Medicare for each service within a given month, in multiple units of 20-minute time blocks.

Practitioners can bill RPM or RTM codes concurrently with other care management services codes as long as time or effort is not counted twice. However, RPM and RTM codes may not be billed together. If the requirements are met for each service, FQHCs and RHCs can bill Medicare for each in a given month.

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2024 G0511 reimbursement rate

The final 2024 payment rate for the general care management HCPCS code G0511 is $72.98. While CMS has updated the rule to reflect multiple billing for G0511, this is a reduction in the reimbursement rate from last year ($77.94 in 2023). However, this reduction should be seen in the context of the overall positive impact these changes will have on providers and their patients, including expanded and  improved access to important services like RPM and RTM, in addition to CCM. Expanded application of G0511 for RHCs and FQHCs to include RPM and RTM is an excellent sign of the growth of coverage for remote care services - expanding the benefits of remote care access into more settings - and with a broader reach into more communities.  

Expansion of RPM and RTM services to RHCs and FQHCs improves access to healthcare for underserved populations in remote areas, supports early intervention of care management, improves patient outcomes and promotes health equity. And while the 2024 reimbursement rate has dropped a bit from 2023, the net gain for patients and providers (and communities) with this expansion is very important. 

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CMS 2024 rule impact for FQHCs and RHCs

These changes empower FQHCs and RHCs to take a holistic approach to patient care, no longer forced to choose between real-time monitoring and long-term management of chronic conditions. These facilities can now offer more comprehensive care, which improves the efficiency and effectiveness of care and generates better outcomes.  It also increases reimbursement and revenue for important services rendered in RHC and FQHC settings.  Improved reimbursement offers a sustainable means to continue these programs allowing more providers and RHCs and FQHCs to expand services and increase revenue to provide and participate in more remote care programs. 

The 2024 RPM reimbursement expansion represents a significant step forward for providers, enabling them to provide more comprehensive and accessible care to their patients. With the potential for increased revenue and improved patient outcomes, FQHCs and RHCs are better equipped to deliver the high-quality healthcare services they have long aspired to provide. The expansion of RPM and RTM services benefits patients and FQHC and RHC providers.

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CMS 2024 expansion’s impact for patients

Expanded remote care management benefits patients with greater remote care options, leading to better health outcomes and allowing the efficiency and effectiveness of remote care solutions to be more broadly available. 

RPM and RTM allows patients to conveniently track their health from the comfort of their homes while enabling timely interventions to prevent hospitalization and ER visits. RPM and RTM programs have been shown to improve patient engagement and connection, and to improve overall health and health outcomes. Expansion to FQHC and RHC patients improves access to healthcare for underserved populations in remote areas, supports early intervention of care management, improves patient outcomes and promotes health equity. 

The 2024 Final Rule reflects a continued maturation of RPM and RTM Medicare billing guidance in general and specifically for expansion for RHCs and FQHCs billing for RPM and RTM. Compliance and accuracy is at the core of our programs and CMS changes and other policies impacting remote care management programs will always be a top priority for how we build and update our programs. Talk to us about how we can help you to incorporate the CMS 2024 final rule into your practice. 

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Sources:

CMS 2024 Final Rule:

https://public-inspection.federalregister.gov/2023-24184.pdf