Remote patient monitoring sees huge utilization increase, but corresponding regulatory spotlight

By Brian Murphy

 

Remote patient monitoring has incredible potential to improve the health of our population… but many providers aren’t billing it correctly, raising the specter of inappropriate utilization or fraud, waste, and abuse.

 

Remote patient monitoring is the use of devices (think blood pressure cuffs, CPAP machines, insulin pumps, etc.) that a physician can monitor remotely and use the data to manage a patient’s condition. Most of the claims are for hypertension, diabetes, and sleep disorders.

 

The number of enrollees receiving remote patient monitoring in trad Medicare multiplied more than tenfold from 2019 to 2022 (55K to more than 570K, respectively).

 

In Medicare Advantage the number of enrollees multiplied 14x.

 

As you’d expect, payments followed suit. In 2019, one year after remote patient monitoring became a separately payable service, Medicare doled out $15M for these services. In 2022, that number skyrocketed to more than $300M.

 

Those kind of numbers will get the OIG’s attention, and it has. We now have a 31-page report on oversight vulnerabilities. See link below. It’s well put-together and well worth reading but here’s my summary.

 

Billing these services requires three components:
 

• Enrollee education and device setup
• Device supply
• Treatment management

 

That’s where the problems start. Some 43% of patients receiving remote patient monitoring did not receive all three components, per the OIG.

 

Layered on over that are the more obvious examples of fraud, for example companies inducing enrollees to sign up, not performing the services but billing anyway.

 

If you’re a coder or CDI professional billing for or otherwise assisting with these claims the OIG provides advice on diagnosis and CPT coding in the report.

 

As you’d expect, you’ll want to stay away from nonspecific ICD-10-CM codes. Medicare requires that remote patient monitoring be used to treat an acute or chronic condition, but the OIG’s audit revealed:
 

• more than 7,000 enrollees with the diagnosis of “other specified counseling”
• more than 500 enrollees with the diagnosis of “other specified health status”
• about 400 enrollees with the diagnosis of “encounter for examination and observation for other specified reasons.”

 

Familiarize yourself with the CPT codes used to bill the three components of remote patient monitoring. These include:
 

• Education and setup (CPT code 99453)
• Device supply (99454)
• Treatment management (99091, 99457, or 99458)

 

I suspect we’re only going to see an increase in the delivery of these services. Hospitals are understaffed, care can increasingly be delivered in the home (for both chronic and in some cases, acute conditions), and technology keeps getting better across the board. Just in the past few years people that I know are now walking around wearing sophisticated insulin pumps that have eliminated the need for strips and needles.

 

These are a good thing, but coding and billing has to follow suit.

 

Are you involved with remote patient monitoring? Send me an email at brian.murphy@norwood.com.