On July 10, 2024, the Center for Medicare and Medicaid Services (CMS) released its 2025 Proposed Rule and Medicare Physician Fee Schedule, outlining potential changes to various healthcare services and reimbursements. The CMS 2025 Proposed Rule did not detail any changes to remote patient monitoring (RPM) or to 2024 RPM CPT codes.
This article explores key takeaways from Medicare’s proposed changes to remote health services.
Primary Care Initiatives
Introduction of Advanced Primary Care Management Services CMS proposes establishing new codes and payment structures for advanced primary care management services (APCM). This would introduce three new HCPCS G-codes that would combine elements from several existing care management and technology-based communication services.
These new bundles are designed to reflect the core components of advanced primary care delivery, including chronic care management, principal care management, and transitional care management.
A new billing opportunity is also proposed for the add-on code G2211. CMS is considering allowing this code to be billed alongside an evaluation and management (E/M) visit on the same day as an annual wellness visit, vaccine administration, or any Medicare Part B preventive service.
FQHCs and RHCs
The CMS 2025 Proposed Rule changes how federally qualified health centers (FQHCs) and rural health clinics (RHCs) are reimbursed for care management services. The change removes the current code G0511 used for RPM and remote therapeutic monitoring services. FQHCs and RHCs would instead use CPT codes for care management services, including the proposed APCM codes if finalized. Payment would be at the national non-facility MPFS payment rate.
Telehealth CMS 2025 Proposed Rule Takeaways
The CMS 2025 proposed rule extends certain telehealth provisions through the end of 2025. This includes the waiver for reporting of enrolled practice addresses instead of home addresses if a provider performs services from home. In addition, the waiver allows FQHCs and RHCs to bill for telehealth services and the requirement for virtual supervision of residents in all teaching settings when the services are provided virtually.
The 2025 Proposed Rule would expand access to behavioral health, oral health, and caregiver training services. It also suggests expanding access to colorectal cancer screening and hepatitis B vaccinations. Additionally, when the telehealth flexibilities expire on December 31, 2024, CPT Codes 99441, 99442, and 99443 will be returned to a bundled status under the proposal.
A significant change is that CMS proposes to update the definition of “interactive communication system” to: “also include two-way, real-time audio-only communication technology for any telehealth service furnished to a beneficiary in their home if the distant site physician or practitioner is technically capable of using an interactive telecommunications system as defined as multimedia communications equipment that includes, at a minimum, audio and video equipment permitting two-way, real-time interactive communication, but the patient is not capable of, or does not consent to, the use of video technology.”
Providing Feedback on the CMS 2025 Proposed Rule
Stakeholder comments are welcomed on the CMS 2025 proposed rule during the 60-day comment period, which will close on September 9, 2024. In early November 2024, CMS will publish the 2025 Final Rule to solidify the path forward for Medicare beneficiaries and healthcare providers.
