The OIG has added RPM to its latest Work Plan. Most urology practices increased their use of new technology and digital care when the COVID-19 public health emergency (PHE) began three years ago. And as you perfect your remote patient monitoring strategy to stay on top of the latest tech innovations, it’s a good idea to also up your game in terms of your coding, billing, and documentation strategy. In fact, the Department of Health and Human Services’ Office of Inspector General (OIG) has added remote patient monitoring (RPM) to its latest Work Plan to ascertain whether any fraud, waste, or abuse is taking place among these services. To ensure you’re reporting these services properly, check out a few key pointers. Understand What RPM Is — and What It Isn’t Remote patient monitoring is an extension of telehealth, in that it allows you to continue the provider-patient relationship even when you aren’t physically together. Although it’s critical to monitor a patient’s vitals during face-to-face visits, for instance, it can also be very helpful to see the arc of that data over a longer time period. If a patient monitors their own health at home and transmits the data directly to the urologist, that information is more readily available. This might include such parameters as blood pressure and blood sugar level monitoring, or voiding diaries. According to CPT® guidelines, RPM devices must meet the Federal Drug Administration (FDA) definition of a medical device, which, per section 201(h) of the Federal, Food, Drug and Cosmetic Act (FFDCA), is “an instrument, apparatus, implement, machine, contrivance, implant, in vitro reagent, or other similar or related article, including any component, part, or accessory … recognized in the official National Formulary, or the United States Pharmacopeia, or any supplement to them.” You can find the FDA guidance at www.fda.gov/regulatory-information/search-fda-guidance-documents/classification-products-drugs-and-devices-and-additional-product-classification-issues#device. Employing RPM typically requires both parties (the clinician and the patient) to have technology, which may be as simple as an app on the patient’s phone, or it could be more intensive. Keep in mind that not every patient can navigate phone apps, so accessibility and ease of use are important factors for practices that are just getting started with RPM. In addition, the data must be protected during transmission and once your office receives the information. What RPM isn’t: RPM isn’t a substitute for the provider’s involvement in the patient’s care. It’s not a robot handling disease management — it’s simply a tool that can allow for better patient monitoring, along with all the other tools at the urologist’s disposal. Codes Don’t Mention Every RPM Scenario To report RPM, you’ll typically submit one of the following codes: Keep in mind that although the descriptors for 99453-99454 do list examples of RPM (such as weight, blood pressure, and pulse oximetry), those aren’t the only allowable options that fall under these codes. As noted above, as long as the FDA considers the device a “medical device” and you meet your payer’s guidelines, then these codes should apply. Consider the Codes’ Intent The RPM codes reflect each step in the data collection process, from setting up the device and teaching the patient how to use it (99453), to supply of the device for daily recording or programmed alert transmissions (99454), to monitoring the data gathered and communicating any information and care plan revisions to the patient based on a provider or other qualified healthcare professional’s interpretation of the device’s data (99457). To report 99453 and 99454, the device must collect and transmit 16 days’ worth of data every 30 days. Keep in mind that this requirement was waived during the PHE, but that’s no longer the case. Therefore, if you don’t have a full 16 days of data for a given month, you cannot report these codes. Warning: “There has been question on the definition of physiologic monitoring,” says Stephanie Stinchcomb Storck, CPC, CPMA, CUC, CCS-P, ACS-UR, longtime urology coder and consultant in Glen Burnie, Maryland. “Some monitoring may not be described by the available codes.” When More Specific Codes Are Available, Report Those Although the codes listed above will apply to many RPM services, they don’t cover everything. If a more specific code applies for your remote patient monitoring, you should report that instead. Some examples include 95250 (Ambulatory continuous glucose monitoring of interstitial tissue fluid via a subcutaneous sensor for a minimum of 72 hours; physician or other qualified health care professional (office) provided equipment, sensor placement, hook-up, calibration of monitor, patient training, removal of sensor, and printout of recording) and 99473 (Self-measured blood pressure using a device validated for clinical accuracy; patient education/training and device calibration). When CPT® rolls out remote uroflowmetry codes in 2024, those will apply as well. (See “Look Ahead to New Neurostimulator, Remote Uroflowmetry Codes in 2024” in Urology Coding Alert Vol. 25, No. 6 for more on these future codes.) Payment May not Be Consistent Not all payers will cover the RPM codes, and payment may not be consistent at first. However, if you get your insurers’ policies in writing up front, you’ll have a much easier time navigating the coverage rules and reimbursement eligibility so you can submit your claims properly and collect faster. If you don’t have your payers’ policies, contact your provider relations representative and ask for the coverage guidelines for RPM services so you can submit clean claims, collect swiftly, and avoid scrutiny. Resource: To read the OIG Work Plan’s addition of remote patient monitoring, visit https://oig.hhs.gov/reports-and-publications/workplan/summary/wp-summary-0000766.asp. Torrey Kim, Contributing Writer, Raleigh, N.C.