Updates on Medicare Reimbursement and Additional Guidance (2024)

OVERVIEW

The following are Medicare Reimbursement resources and reference documents concerning:

• • Telehealth (interactive video/audio or audio-only)
  • eConsults
  • Remote physiological or therapeutic management
  • Store and forward (in limited circumstances)

Please note that general Medicare payment policies do not apply to Federally Qualified Health Centers, Rural Health Clinics, and Indian Health Clinics.  Please see discussion for information on FQHC, RHC, and IHC policies.

GENERAL TELEHEALTH (INTERACTIVE VIDEO-AUDIO AND AUDIO-ONLY)

• • • Telehealth (interactive video-audio and audio-only)
    • Medicare Cost Year 2024 List of Telehealth (interactive video/audio and audio-only covered services)
    • Medicare Learning Network: Telehealth Services Fact Sheet (February 24, 2024)
    • Medicare Learning Network: Updated Medicare Payment Cost Year 2024  (January 1, 2024)

GENERAL REMOTE PHYSIOLOGICAL MONITORING

Medicare covers remote physiological monitoring.  Medicare policies include:

• • • An established patient-physician relationship is required
    • Consent to receive remote physiologic monitoring services at the time services are furnished is allowed
    • Physicians and non-physician practitioners who are eligible to furnish evaluation and management services (E/M) may bill for remote physiologic monitoring services

Guidelines for remote physiologic monitoring services billed to CPT codes 99453 and 99454

• • • Physiologic data must be electronically collected and automatically uploaded to the secure location where the data can available for analysis and interpretation by the billing practitioner
    • The device used to collect and transmit the data must meet the definition of a medical device as defined by the FDA
    • Remote physiologic monitoring data must be collected for at least 16 days out of 30 days
    • Remote physiologic monitoring services must monitor an acute care or chronic condition
    • The services may be provided by auxiliary personnel under the general supervision of the billing practitioner

For specific codes and requirements for Medicare’s remote physiologic monitoring coverage, visit the Medicare Physician Fee Schedule page from the Centers for Medicare & Medicaid Services.

RURAL HEALTH CLINIC OR FEDERALLY QUALIFIED HEALTH CENTERS

Telehealth (Interactive Video-Audio or Audio-Only) 

Any service that Medicare has approved to be furnished via telehealth can be provided by an FQHC or RHC through December 31, 2024.

• • • For the full list of telehealth services, including which services can be provided as audio-only visits, see this list of telehealth services from the Centers for Medicare & Medicaid Services.
    • RHCs and FQHCs can bill Medicare for telehealth services as distant site providers.
    • Patients can receive telehealth services in their home.

Use the following Healthcare Common Procedure Coding System (HCPCS) codes and Current Procedural Terminology (CPT) codes:

Source: Rural Health Clinics and Federally Qualified Health Centers and MLN Matters New & Expanded Flexibilities for Rural Health Clinics & Federally Qualified Health Centers

Remote Physiological Monitoring and Remote Therapeutic Monitoring

Starting January 1, 2024, FQHCs and RHCs are authorized to receive payment for RPM and RTM outside of the RHC all-inclusive rates and the FQHC per visit payments.

• • • Under the general management code HCPCS G0511, FQHCs and RHCs will be able to receive payment for Remote Patient Monitoring (RPM) and Remote Therapeutic Monitoring (RTM)services, expanding the code, which already included other inherently non-face-to-face services like Chronic Care Management and behavioral health integration services.

• • • RTM is designed for the management of patients under a specific treatment plan using medical devices that collect non-physiological data related to signs, symptoms, and functions of a therapeutic response.  The structure and nature of RTM services resemble RPM services.  While there are similarities, there are notable differences.

Virtual Communication Services

Virtual Communication Services are covered, including online digital evaluation and management, which are broadly defined as digital communications that are patient-initiated using a secure patient portal.

Virtual communication services are reimbursed at a different rate since they are not defined as telehealth services by the Centers for Medicare & Medicaid Services.