Last week, the Centers for Medicare and Medicaid Services (CMS) released the 2024 Physician Fee Schedule (PFS) Proposed Rule. The annual rule announces rate updates and policy changes for Medicare payments under the PFS, and other Medicare Part B coverage and payment regulations, effective on January 1, 2024.
Below are a few notable updates relevant to providers using Remote Therapeutic Monitoring (RTM) for musculoskeletal (MSK) services:
- General supervision of outpatient therapy services for PTs and OTs in private practice: This represents a very important detail in the 2024 Proposed Rule with respect to RTM. CMS is proposing to establish an RTM-specific general supervision policy to allow physical therapists in private practice (PTPPs) and occupational therapists in private practice (OTPPs) to provide general supervision only for RTM services furnished by their PTAs and OTAs, respectively. This supports remote therapeutic monitoring management services to be performed outside of the clinic, which is instrumental to providing comprehensive at-home support for patients.
- RTM Coverage in RHCs and FQHCs: CMS proposes to include RTM along with other care management services into HCPCs code G0511, a general care management services code for Rural Health Centers (RHCs) and Federally Qualified Health Centers (FQHCs). Expansion of RTM services to RHCs and FQHCs improves access to healthcare for underserved populations in remote areas, supports early intervention of conservative treatments, and promotes health equity.
- RTM Coverage During Surgical Global Periods: CMS proposes to clarify that an individual beneficiary may receive a procedure or surgery, and related services, that are covered under a payment for a global period, and also receive RTM services. The provider would receive payment for the RTM services separate from the global service payment. From the Proposed Rule: “We are proposing to clarify that, in circumstances where an individual beneficiary may receive a procedure or surgery, and related services, which are covered under a payment for a global period, RPM services or RTM services (but not both RPM and RTM services concurrently) may be furnished separately to the beneficiary, and the practitioner would receive payment for the RTM or RPM services, separate from the global service payment, so long as other requirements for the global service and any other service during the global period are met.”
Please note: This blog is for informational purposes only, does not constitute billing or legal advice, and includes a review of information about the 2024 CMS Proposed Rule yet to be finalized, which is publicly available here and here.