Remote patient monitoring (RPM) has revolutionized healthcare by enhancing access to care, improving patient outcomes, and reducing provider costs, particularly when it comes to chronic care management. Successful RPM programs offer clarity over patient data, including vitals like blood pressure and pulse ox, to identify early warning signs of potential health conditions. As this innovative technology continues to evolve, however, providers must be sure to maintain RPM compliance with billing codes and other industry regulations. Here are the factors they should keep in mind when partnering with an RPM vendor.
Compliance, Coding, and Billing
If an RPM vendor relies solely on digital activities and no telephonic contact between a nurse and a patient, they could be violating billing codes. Equally concerning is if a vendor promises to handle all work and allows you to bill, which may violate the requirement for general supervision.
Billing practices extend to whether vendors bill only for patients who meet a certain Current Procedural Terminology (CPT) code threshold. This could potentially induce improper billing.
Another crucial aspect is patient interaction. According to billing codes 99457 and 99458, RPM services must include live patient interaction over the phone or through video conferencing. You’ll need to verify that your vendor’s services offer these capabilities.
RPM Device Prices
Providers should understand the financial model of the RPM services they select. Some vendors may offer free devices while others will charge for them. Comparing this against your available budget will help you decide whether these devices are financially feasible to implement and maintain.
Reporting
You’ll need to define who will be reviewing patient data from your RPM medical devices and generating the minutes for triage, whether nurses or medical assistants (MAs). Similarly, the scope of their duties will need to be clarified: are they limited to clerical tasks only, or will they have more active roles in patient care?
Location of Services
If a vendor’s services are generated offshore, this could violate CPT code reimbursement guidelines.
Contracts
Contracts and written agreements are fundamental to maintain compliance. Vendors should provide a written contract, as failing to do so could be a violation. Furthermore, vendors should provide a clear statement of work outlining roles and responsibilities — especially if parts of the program are outsourced under general supervision, a requirement set by the Office of Inspector General (OIG).
Staffing
RPM call centers should be staffed with registered nurses and/or licensed staff who are authorized to provide program oversight in the state where they operate.
Summary
Here’s a quick recap of all of the points discussed above as a helpful checklist you can use for evaluating potential RPM vendors and their compliance:
- Does the vendor charge for their RPM devices, or are they provided for free?
- Are the minutes for triage generated by nurses or medical assistants (MAs)?
- Are MAs limited to performing only clerical tasks, or do their responsibilities extend beyond them?
- Does the RPM service include live interaction with patients by phone or video to comply with codes 99457 or 99458?
- Is the vendor relying solely on review activities for billing minutes?
- Is the vendor promising to handle all of the work and allow you to bill?
- Does the vendor only bill for patients who meet a specific CPT code threshold?
- Are any of the vendor’s billable services being generated offshore?
- Does the vendor provide a written contract to formalize your agreement?
- Does the vendor provide a clear statement of work outlining roles and responsibilities, especially if any aspects of the program are outsourced under general supervision?
- Are call centers staffed with nurses or licensed staff authorized to provide program oversight in the state where they operate?
The choice of an RPM vendor extends beyond functionality and cost, reaching into the realm of regulatory compliance and patient safety. The checklist above serves as a crucial tool for healthcare providers to ensure that all aspects of an RPM service adhere to stringent standards, from device provision to billing.
These questions require in-depth answers, not mere acknowledgment. Compliance is not simply about avoiding penalties, it’s about ensuring the highest standards of care. In your search for the right RPM vendor, prioritize patient safety and compliance, and remember that a thorough understanding today can prevent potential issues tomorrow.
If you have questions about this checklist or other factors involved with RPM and patient engagement, we’d like to hear from you.
About TriageLogic
TriageLogic is a URAC-accredited, physician-led provider of top-quality nurse telehealth technology, remote patient monitoring, and medical call center solutions. Founded in 2007, the TriageLogic Group now serves more than 22,000 physicians and covers over 42 million lives nationwide.
