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.

HIPAA compliant email vs HIPAA compliant texting

Emailing is not the primary form of communication amongst younger generations. As a millennial, it’s fair to say that we are always on our phones. Whether we are using it to text, check Facebook, use Snapchat or Messenger it’s abundantly clear that we use our phones to quickly send messages to our friends and colleagues. Emails still play a crucial role in the working world today, but it is not the most efficient way if we want to talk to someone get an immediate response, a text message is way more efficient.

How does this healthcare come into play?

For starters, most of the time we want to schedule an appointment with a doctor we will call our local practice listen to the general voice mail and eventually talk to a receptionist once the line is free. Once we go in for our appointment we get a diagnosis and a prescription if necessary and then go home and tend to our illness. In most situations after we leave the practice some lingering questions come up that weren’t ask during the appointment. How can we talk to our doctor to get those questions answered? There’s email but a busy practice will not have the time to sit down at their computer and formulate an response email. They are much more likely to answer a text message quickly in between patients or when there is short downtime.

Why don’t doctors text message?

They do! But the problem with text messaging protected health information(PHI) over SMS is that it’s not secure. If a doctor is sending PHI over SMS he/she is in violation of HIPAA and liable for $50,000 fine. HIPAA was not as much of a big deal until 2003 when the Privacy Rule required compliance. Many practices see the value in texting patients to set up appointments and overall educating patients about their certain ailments. It allows for practices to be able to reduce phone tag and the amount of time patients are kept waiting on hold. Communications within the medical field is changing and text messaging will become an efficient way for people to communicate with their practices.

Making texting HIPAA compliant for Health Professionals and Patients

In this day and age it seems like everyone has a smartphone. One of the most popular ways to use our smartphones is to text. According to a Gallup Survey, texting is the most popular way of communicating for Americans under the age of 50. With younger generations continuously using their smartphones for communication with friends and family members it’s a natural progression to begin using text to communicate with their healthcare providers.

Being able to text your local clinician/doctor for simple questions like clarification on prescriptions and dosages is a game changer. This gives you a medium you can consistently refer back to with clear written instructions, and you don’t need to worry about misplacing the prescription itself.  It also provides patients with a great opportunity to get clarification on other instructions and care plans the doctor may have shared during an office visit.  It often happens that you receive so much information in a visit to the doctor’s office that you forget to ask important questions, and OhMD gives patients a tool to get those lingering questions answered quickly and easily.

The logical concern with texting is security. With the new demand for the convenience of texting comes privacy and security concerns.

If you are already in contact with your healthcare provider and are using SMS texting, you are violating HIPAA.

When it comes to HIPAA compliance, texting using the default texting app is not an option. Even though major cellphone carriers offer encryption on data being sent through their servers, text messages remain on the device.

If your phone is lost or stolen your protected health information (PHI) could be compromised.

In addition to losing your phone anyone can access your messaging app if they have access to the contents of your phone. Even if you have a password on your phone, think about all the people you let use your phone to make calls or text themselves so they have your number.  All those people could easily access your messages with your healthcare provider.

OhMD not only offers a HIPAA certified texting platform, it’s also free.  As a patient you can download and use OhMD for free to communicate with all of your healthcare providers that have the app — your primary care physician, your dentist, your counselor or your home health aid.  For patients who are accustomed to having their health data in many different places, this is a welcomed change.

Although there are valid concerns regarding HIPAA compliance, texting applications like OhMD offer a secure solution for patients and their care providers to communicate quickly and easily.

Efficient Doctor-Patient Communication

The single largest budget item for hospitals is labor costs, which can represent as much as 50% or more of the expense budget.  In small practices staff salary and benefits account for up to 30% of overhead expenses.  To get the most out of their largest line item, large and small healthcare organizations alike should be focused on staff efficiency, especially in doctor-patient communication.

A big opportunity to improve efficiency is to improve communication — doctors are still using pagers for goodness’ sake.  The problem is that most organizations find the prospect of implementing new technology daunting.  The transition to electronic medical records left scars on many practices who were forced to fundamentally change their workflow, but the transition to technology that enhances communication is actually pretty easy.

Texting technology doesn’t require providers and staff to change their workflow.

Secure texting is the best way for practices to both engage with their patients and communicate internally.  Most doctors are already texting with their colleagues, staff and referring providers, and providing a secure channel to maintain that flow of communication will help avoid costly HIPAA fines.  It’s a no-brainer.  It’s the part about texting patients that gets practices really worried.

“Why would I want to open that floodgate?”  

“I don’t want my patients to be able to contact me directly.”

“My staff already have enough to do.”

But the reality is that providing a secure texting channel built for healthcare can actually solve these problems.  Secure texting makes doctor-patient communication more efficient.

It’s like a phone call, only easier.

Most physician practices and hospital groups that use OhMD implement a workflow that mimics their phone call workflow.  Because the majority of patients preferring texting to calling, many practices see a reduction in call volume by up to 30% in the first 12 months.  And since phone calls take more time to answer, triage and follow-up on than a simple text message, the reduction in call volume represents a huge increase in staff efficiency and productivity.

Patients are likely to text practices about a whole range of things, from scheduling appointments, to prescription refills, to more clinically significant questions. This means that doctor-patient communication more often ends up being practice-patient communication, with the physician only fielding a small percentage of patient texts.

Doctor-Patient communication for the 21st century.

Medical practices should be thoughtful about the technology they implement; there is too much on the line when it comes to security, patient satisfaction and efficiency for practices to chase every technology fad.  But texting isn’t going anywhere.  Practices who value efficiency and patient engagement need to implement a secure texting solution to optimize communication.

Video: OhMD is all about simple communication for healthcare

We’ve made communication simple with a HIPAA compliant texting app that changes the patient experience. Check it out!

OMG – texting with patients

OhMD and one of our physician users, Dr. Julio Bracero-Rodriguez, was recently featured in an article in athenainsight about texting with patients!

Check it out here: https://insight.athenahealth.com/omg-%E2%80%94-text-doctor

Text Messages > Voice Messages

There is no question that text messages are the preferred form of communication for the majority of the adult population in the US (and globally).  As healthcare begins its shift toward a more consumer-centric paradigm, providers and organizations must find a secure way to meet patients where they are: on their phones.

Let’s start by looking at the facts about smartphone usage and texting:

  • 90% of all adults in the US own a cell phone
  • 99% of text messages are read within the first 90 seconds
  • 68% of adults in the US own a smartphone
  • 97% send and receive text messages
  • Even adults >65 send an average of 5+ texts/day
  • 80% of patients want to text with doc according to a study by FICO
  • 62% of smartphone owners have used their phone in the past year to look up information about a health condition

The death of voicemail

Dermatology practice consultant Amelia Coleman

Written by Amelia Coleman, Physician Practice Consultant

Many organizations across industries are recognizing the inefficiencies associated with voicemail and are implementing major changes to business as usual.  Employees are increasingly mobile, and the cost associated with voicemail technology and follow-through is high.  Last year JP Morgan Chase & Co. decided to eliminate voicemail for its almost 140,000 consumer-bank employees.  At $10/line plus the employee time associated with managing voicemails will save the company an estimated $2 billion in annual expenses.

In contrast to text messages, which are often read within 90 seconds of receipt, people dislike phone calls and neglect their voicemail 80% of the time.  Texting is more personal, it’s not as interrupting, and it gives the receiver control over how long a conversation takes.

In practices that have implemented OhMD, we see an average of a 30% reduction in overhead costs associated with call volume.  Patients love texting their practice. In fact, our studies show that 97% of patients using OhMD prefer it to calling the practice.

The Free Healthcare App Making Waves

OhMD is a new healthcare app revolutionizing communication in healthcare for free. Until now, conversations between physicians and their teams were relegated to slow and inefficient channels. A telephone call often turned into a voicemail, which often turned into a game of phone tag that would ultimately waste valuable time every day. While texting has been a preferred channel of communication outside of healthcare, HIPAA rules prevent the use of SMS or even encrypted texting apps like Whatsapp in the industry.

The OhMD app gives healthcare professionals a way to communicate protected health information (PHI) over a HIPAA secure texting platform. A physician can use OhMD to send any text message that needs to go over a HIPAA secure channel. It can be used by any healthcare professional to communicate with any other provider, within or outside any organization.

And for those forward-looking practices searching for more efficient ways to communicate with patients, OhMD does that too.

Practices can use the app to proactively reach out to all their patients, a subset of patients, or one patient at a time. Most practices are inundated with patient calls from open to close, so texting allows practices to reach patients in a far more efficient way. So instead of phone tag with patients to reschedule an appointment or to answer a clinical question, it’s a quick text message. Practices see as much as a 30% reduction in call volume and an instant increase in patient engagement as well as patient satisfaction.

The app is designed to protect patient information through the use of bank-grade encryption and centralized account management. All protected health information is securely stored in an encrypted database and no sensitive information is stored on user devices. If a user were to misplace their smartphone, not only is their OhMD account protected by a password and/or pin code, but their account can be disabled remotely.

The value of texting in healthcare stems from its simplicity.

The app was created to address a pervasive problem in healthcare: the inefficiencies around communications. With OhMD, patients can contact doctors and practices more efficiently with a simple, HIPAA secure text message, while also giving doctors a way to securely text with other doctors and colleagues. 

The platform was created by healthcare industry veterans for healthcare professionals and is being used across specialties by healthcare professionals of all types. Phone tag, high phone traffic and voicemails are soon to be a thing of the past, and texting in healthcare is the future.