Remote physiologic monitoring (RPM) is improving health outcomes while reducing costly hospitalizations, saving money for federal taxpayers. As mentioned in our pre-rulemaking letter, we appreciate the opportunity to work with CMS to ensure accurate reimbursement and regulation that reflects the returns RPM is delivering for both patients and taxpayers.
The Trump Administration took decisive action to expand Medicare access to RPM in 2019, laying the groundwork for technology-enabled chronic disease management and transforming how care is delivered to seniors. The Council generally applauds the Administration for its commitment to modernizing the current fee-for-service structure to better reflect the fast pace of digital health technologies, such as RPM.
As reflected in the comments below, the Council:
- Supports the CMS proposal to value 99454 and other technology-based RPM codes using OPPS data on an interim basis, but strongly encourages the Administration to 1) make clear that the ultimate goal remains to update and modernize the practice expense calculation to improve practice expense for codes like 99454, and 2) Revise the proposal to use more up-to-date CY2026 geometric mean cost (GMC) data and maintain this valuation until a more accurate valuation methodology is determined. We request that CMS work with industry to modernize practice expense calculations for RPM.
- Supports the implementation of new RPM codes for less than 16 days of data transmission and less than 20 minutes of interactive communication per month: CPT codes 99XX4 and 99XX5. We provide more detailed responses below.
- Urges CMS to consider an add-on code for patients with highly complex chronic conditions or a valuation adjustment for RPM treatment management services to reflect the highly complex nature of patients with multiple comorbidities and the impossibility of managing one condition well without also managing concurrent conditions.
- Encourages CMS to move forward with best practice recommendations for the delivery of RPM services that will ensure high-quality, high-value patient care and driving clinical outcomes that reduce overall spending for the American taxpayer.
- The Council believes RPM and RTM valuation should remain separate for the time being, at least until clinical use cases and evidence around the services demonstrate differently.