The 2023 CMS Physician Fee Schedule Final Rule is now in effect. And, while the changes weren’t as far-reaching as last year’s, the new guidelines do have some important changes for telehealth in general, as well as remote therapeutic monitoring (RTM) specifically. In addition, a new model of Chronic Pain Management (CPM) could expand billable services for remote patient monitoring (RPM) programs.
Issued each year by the Centers for Medicare and Medicaid Services (CMS), the Physician Fee Schedule defines the specific services eligible to receive federal reimbursement. As such, it’s also the de facto setting for much of the pricing adhered to by private insurers. Let’s take a closer look at the 2023 Final Rule, and what providers of RPM and RTM services should know about it.
What’s the difference between telehealth and RPM? Get a primer here
2023 CMS Physician Fee Schedule introduces HCPCS codes for Chronic Pain Management (CPM)
Although the Final Rule has not changed the details for RPM, it has introduced a new model that can be used in coordination with it. With new codes for Chronic Pain Management (CPM), CMS now provides reimbursement for time spent managing patients with chronic pain on a monthly basis, thus offering a more comprehensive and holistic framework for treating chronic conditions.
Defining “chronic pain” as “persistent or recurrent pain lasting longer than three months,” the two new HCPCS codes, G3002 and G3003, cover a vast range of potential services to manage that pain, including:
- Assessment and ongoing monitoring
- Administration of a “validated pain rating scale or tool”
- General treatment management
- “Development, implementation, revision, and/or maintenance of a person-centered care plan that includes strengths, goals, clinical needs, and desired outcomes”
- Medication management
- Health and literacy counseling
- “Facilitation and coordination of any necessary behavioral health treatment”
- Ongoing coordination and communication “between relevant practitioners furnishing care, e.g., physical therapy and occupational therapy, complementary and integrative approaches, and community-based care, as appropriate”
- Any other “necessary chronic pain-related crisis care”
An in-person visit of at least 30 minutes must be billed as G3002 (CMS has clarified that telehealth technology can be used as a substitute when necessary). And each follow-up service lasting for 15 minutes or more is reimbursable under G3003, which can be billed “an unlimited number of times (as medically necessary),” according to an analysis by J. Taylor & Associates, LLC.
“CMS is not limiting the types of physician specialties, or the types of qualified health professionals, who can furnish CPM services, as long as they can furnish all of the service elements of HCPCS code G3002, including prescribing medication as needed, within their scope of practice in the State in which the services are furnished,” the CMS news release clarifies.
“Any of the CPM in-person components included in HCPCS codes G3002 and G3003 may be furnished via telehealth, as clinically appropriate.”
“CMS received comments asking the agency to clarify if the proposed CPM services would be available for billing/reporting in conjunction with RPM and RTM codes,” explain the experts at Powers Pyles Sutter & Verville PC. “CMS clarified that the RTM, RPM, and CPM are distinct services and that the CPM codes could be billed for the same patient in the same month as the RPM and RTM codes.”
2023 CMS Physician Fee Schedule: Changes to remote therapeutic monitoring (RTM)
In addition to expanding the potential concurrent services for patients with chronic respiratory conditions by adding chronic pain management to remote therapeutic monitoring (RTM), the new Final Rule also expands reimbursement for remote therapeutic monitoring in a few ways — including the addition of a new code allowing for devices that monitor cognitive behavioral therapy.
Currently marked as CPT 989X6, the new code doesn’t yet have a reimbursement amount assigned to it, with CMS assigning local Medicare administrative contractors (MACs) to handle pricing independently at this point. While this may lead to some confusion, especially in the early months of 2023, it’s still a step in the right direction of expanding what’s already frequently been a successful model of care.
What is Remote Therapeutic Monitoring (RTM)? Find out here
First introduced in the 2022 Final Rule, the five existing CPT codes for RTM covered the supply of devices that monitor and collect respiratory and musculoskeletal data. Not only does the new code expand the range of available services by adding cognitive behavioral therapy, but the new Final Rule also expands the range of eligible billing practitioners by clarifying that any RTM service may be provided under general supervision requirements.
This is a development that’s been closely watched. In the first draft of the Proposed Rule (which later became the Final Rule), CMS proposed to solve the problem of limited access by changing the current CPT codes into a series of new HCPCS codes. The agency abandoned that idea in response to feedback during the comment period.
“This is a big win for RTM services as easing supervision requirements should encourage increased provision of the services,” writes Daniel Tashnek, JD at Medical Economics. “Yet, some questions remain concerning who this declaration applies to as there are existing restrictions on incident-to billing for some provider types that can bill for RTM. We hope to receive clarification on this point soon.”
Tashnek also points out how, unlike RPM, which does not tie reimbursement to a specific device, CMS is insisting on doing so for RTM, hence the new 989X6 code. It’s “unclear whether generic device codes would undermine or stall progress toward a wider set of specific codes that would provide less ambiguity,” the agency explains (though Tashnek expects a “continued push for the creation of such a code.”)
Other telehealth adjustments in the 2023 CMS Physician Fee Schedule
The 2023 Final Rule impacts telehealth in a few other significant ways. One of its priorities seems to be finalizing the telehealth services that it deems to be successful during the Covid-19 public health emergency (PHE). Specifically, it seeks to extend these services “at least through CY 2023,” as the agency stated in the news release announcing the Final Rule.
Specifically, the Final Rule specifies that all services “temporarily included on the telehealth services list” for the PHE will be active “for at least a period of 151 days following the end of the PHE.” However, this development may be largely moot in light of the passage of the omnibus bill and its extension of the PHE telehealth waivers through December 31, 2024.
The CMS announcement also confirms the goal of ensuring “a smooth transition after the end of the PHE” in the form of a number of policies, like easing restrictions on geographic originating sites, allowing some services to be provided via audio, and “allowing physical therapists, occupational therapists, speech-language pathologists, and audiologists to furnish telehealth services.”
Despite some requests to do so, CMS chose not to add a series of proposed services such as therapy and behavioral treatment and identification to its list of Category 1 and 2 Medicare telehealth services. However, some similar services like biofeedback, brain nerve neurostimulation, and some ophthalmologic and audiology services did get added to the Category 3 telehealth services.
Created under the 2021 Final Rule and set to run through December 31, 2023, Category 3 is a temporary classification that will ensure that some telehealth services will be furnished for another calendar year, and not end with the PHE, which will likely conclude before January 2024.
CMS also denied a request to add telephone E/M services of CPT codes 99441, 99442, and 99443 to the telehealth list. Because those services have always been “inherently non-face-to-face,” they are not designed to replace in-person care, which is the basis for telehealth services.
“CMS acknowledged that audio-only technology can continue to be used to furnish mental health telehealth services to patients in their homes after the PHE ends,” the Powers Pyles Sutter & Verville authors add, “but that after the PHE, two-way, audio-video communications technology is the appropriate standard that will apply for Medicare telehealth services that are not mental health services.”
Guidance on CMS Physician Fee Schedule changes and more from CareSimple
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