Primary Care Coding Alert

Reader Questions:

Monitor This Commonly Misunderstood RPM Rule

Question: Our provider thinks one of our patients is eligible for the remote physiologic monitoring (RPM) program. However, her conditions are not chronic. Only patients with chronic conditions can receive RPM services, correct?

Michigan Subscriber

Answer: RPM services are not limited to patients with chronic conditions, though your misunderstanding is a common one.

The Centers for Medicare & Medicaid Services (CMS) published guidance back in 2019 that initially determined patients with chronic conditions could be the recipients of RPM services. Then, in the 2021 Medicare Physician Fee Schedule (MPFS) final rule, CMS amended the wording to say that practitioners may “furnish these services to remotely collect and analyze physiologic data from patients with acute conditions as well as from patients with chronic conditions” (see the 2021 Final Rule at www.cms.gov/files/document/12120-pfs-final-rule.pdf).

Note that CMS does limit RPM services to established patients, but that limitation was waived for the duration of the public health emergency (PHE). It should also be noted that CPT® does not outline such a limitation.