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Ask a Rev Cycle Expert: COVID Remote Patient Monitoring Billing?

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Question:

Would it be appropriate for a HOPD to bill for 99453 and 99454 for remote patient monitoring (RPM) for patients discharged from the hospital with intent to monitor COVID symptoms/vitals via pulse oximetry? Vitalware shows applicable Revenue codes as 0510 for Clinic, would this be accurate for a hospital?

Answer:

Current Procedural Terminology (CPT®) codes 99453, Remote monitoring of physiologic parameter(s) (eg, weight, blood pressure, pulse oximetry, respiratory flow rate), set-up and patient education on use of equipment, and 99454, Remote monitoring of physiologic parameter(s) (eg, weight, blood pressure, pulse oximetry, respiratory flow rate), initial; device(s) supply with daily recording(s) or programmed alert(s) transmission, each 30 days, may be reported by hospital outpatient departments (HOPDs) in accordance with guidance published by the Centers for Medicare & Medicaid Services (CMS) and with the Official Coding Guidelines for remote physiologic monitoring.

According to guidelines found in the “Remote Physiologic Monitoring Treatment Management Services” subsection, RPM services are provided when clinical staff, physicians, or other qualified health care professionals use the results to manage a patient under a specific treatment plan using a medical device as defined by the FDA. Additionally, the service must be ordered by a physician or other qualified health care professional.

Additional guidance regarding use of RPM during the COVID-19 public health emergency (PHE) can be found in Transmittal R1016OTN which states, “CMS made several changes to RPM policies in response to the PHE for COVID-19. (1) We removed the requirement that there be an established patient-practitioner relationship. Both new and established patients can receive RPM services. (2) We modified the requirement that consent must be obtained prior to furnishing the RPM service. Instead, consent can be obtained at the time services are furnished and by individuals providing PM services under contract to the ordering physician or qualified healthcare professional. (3) We clarified that RPM services can be used for physiologic monitoring of patients with acute and/or chronic conditions. (4) We confirmed that RPM services can be furnished under general supervision. (5) For CPT codes 99453 and 99454, we modified the number of days that data must be collected from the required 16 days to fewer than 16 days in a 30-day period as long as the other code requirements are met.

Because remote physiologic monitoring can be used for patients with acute and/or chronic conditions, monitoring COVID-19 symptoms would be an appropriate indication so long as the other code requirements are met. At the current time, CPT® code 99453 is assigned a status indicator of V (Clinic or Emergency Department Visit) under the Outpatient Prospective Payment System and has a national unadjusted payment rate of $115.93. CPT® code 99454 is assigned a status indicator of Q1 (STV-Packaged Codes) under the Outpatient Prospective Payment System, meaning it is separately payable when not reported with another significant procedure or clinic visit service with a national unadjusted payment rate of $36.25.

The revenue code assigned for this service should reflect the location where the charges are incurred for appropriate allocation on the facility’s cost report.

Disclaimer: This information was current at the time of its publishing and is designed to provide accurate information in regard to the subject matter covered. Vitalware does not accept any responsibility or liability with regard to any errors, omissions, misuses, or misinterpretation by the reader. It is not intended to take the place of either the written policies or regulations. We encourage you to review the specific regulations and other interpretive materials as necessary. All CPT® codes are trademarked by the American Medical Association (AMA) and all revenue codes are copyrighted by the American Hospital Association (AHA).