The CMS RPM Reimbursement Rule – Getting paid to text patients

Why texting for RPM reimbursement?

Physicians rarely text patients. If you ask a physician why they don’t use texting for patient care, they will respond in one of the following ways:

  • “My patient portal has messaging but nobody uses it.”
  • “Why would I want patients texting me at all hours of the night?”
  • “Nobody pays me to text patients”

Each one of those responses has some degree of merit. However, the improvement in the technology you as a physician has access to helps to address the first two points:

The patient portal argument.

Almost all patient portals do have a “messaging” feature. Unfortunately, portal “messaging” is more akin to secure email than it is texting. Texting is what your patients really want. It’s also likely buried in a laundry list of other features a patient may or may not use. And, those features are all behind a cumbersome registration process with a less than friendly user-experience. Patients have come to expect better from the consumer apps they use every day.

Remote patient monitoring with text

The “texting all hours of the night” argument.

You already work long hours. Very few physicians want to respond to patient texts at home during dinner. Great news though, OhMD has the ability to set office hours, and away messages. You can also build care teams that mirror today’s call flows. You never need to respond from home if you don’t want to.

The reimbursement argument. (this is the big one)

Until recently, there was no good way for the majority of providers to submit for CMS reimbursement for communicating with patients between visits. However, that’s all about to change.

The new RPM billing codes (Remote Patient Monitoring)

On July 12th, 2018, CMS released a proposal focused on limiting the administrative burden for physicians while compensating them for taking steps to use new technologies, now also known as RPM technology, to communicate and diagnose their patients. Medicare and Medicaid’s proposed physician fee schedule for 2019 paves the way for RPM reimbursement for texting with patients, and even with peers.

Here’s how these RPM “Virtual Care Codes” are shaping up so far:

RPM billing codes and Virtual Check-ins (CPT code 99453, 99454, and 99457)

This proposal details a new payment code for “Brief Communication Technology-Based Services”. That is, if you’re using a digital communication platform, or texting with patients with a HIPAA compliant solution. Under this proposal, you’ll be able to bill for a virtual check-in. CMS goes further by describing RPM services as a “brief non-face-to-face check-in with a patient via communication technology, to assess whether the patient’s condition necessitates an office visit.”

The proposal outlines that this code would be used for texting or messaging with established patients only, and wouldn’t be a replacement for an in-person visit. This would be reflected in the proposed RPM reimbursement rate, which would be lower than the reimbursement for a live office visit.

Within the proposed virtual check-in description, CMS plans to reimburse providers that use a patient communication solution like OhMD to text with patients for “5-10 minutes of medical discussion”.

Remote Evaluation of Pre-Recorded Patient Information (HCPCS code GRAS1)

This code will allow for RPM reimbursement to any provider that reviews “recorded video and/or images captured by a patient in order to evaluate the patient’s condition”. This will also be used primarily for established patients. There may also be specific instances where the code could be used for new patients.

Interprofessional Internet Consultation (CPT codes 994X6, 994X0, 99446, 99447, 99448, 99449)

The idea of compensating physicians for peer-to-peer consultations is a popular one. Physicians must communicate efficiently with their colleagues to provide the highest level of patient care. These CPT codes for texting between physicians is an exciting step in the right direction to compensate providers for the time they spend on care coordination.

CMS details what they consider a peer-to-peer consultation as “Assessment and management services conducted through telephone, internet, or electronic health record consultations furnished when a patient’s treating physician or other qualified healthcare professional requests the opinion and/or treatment advice of a consulting physician or qualified healthcare professional with specific specialty expertise to assist with the diagnosis and/or management of the patient’s problem without the need for the patient’s face-to-face contact with the consulting physician or qualified healthcare professional.”

Until September 10th, 2018, CMS will be soliciting comments here: https://www.regulations.gov/document?D=CMS-2018-0076-0001

Update: November 2, 2018

This proposal is moving forward and you can expect it to begin on January 1, 2019. Remote patient monitoring may play a significant role in improving patient communication between visits. As long as RPM reimbursement is significant enough to justify the cost of implementing a system, this will be great for patients and providers.