Posts tagged CMS
CMS Finalizes APCM Codes for 2025: What it Means for Primary Care and Digital Health Companies
CMS Finalizes APCM Codes for 2025: What it Means for Primary Care and Digital Health Companies

CMS has finalized the APCM codes for 2025. See what this means for primary care and digital health companies.

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Medicare Physician Fee ScheduleCarrie Nixonremote patient monitoring, Telehealth, Medicare, Teleheath, Digital Health, behavioral health integration, mpfs, medicare physician fee schedule, remote therapeutic monitoring, digital health, mental health, telemental health, DMHT, APCM, CMS, MPFS, codes
Proposed Changes to Remote Therapeutic Monitoring Reimbursement in the Proposed 2023 Medicare Physician Fee Schedule
Proposed Changes to Remote Therapeutic Monitoring Reimbursement in the Proposed 2023 Medicare Physician Fee Schedule

Stakeholders will be glad to know that CMS continued the RTM conversation with stakeholders beyond last year’s 2022 Medicare Physician Fee Schedule Final Rule (the “2022 Rule”) and directly addressed many of our questions and concerns, including NGL’s recommendations to re-visit the overall code structure to better align RTM with Remote Physiologic Monitoring (“RPM”) and other care management services.

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Remote MonitoringKaitlyn O’Connor, Carrie Nixon, and Casey PappRTM, Remote Therapeutic Monitoring, MPFS, 2023 MPFS, CMS, reimbursement, CPT codes
Top Six Takeaways from the Proposed 2023 Medicare Physician Fee Schedule: New Remote Monitoring, Behavioral Health, and Chronic Pain Care Management Codes and Telehealth Flexibility Extension
Top Six Takeaways from the Proposed 2023 Medicare Physician Fee Schedule: New Remote Monitoring, Behavioral Health, and Chronic Pain Care Management Codes and Telehealth Flexibility Extension

The much-anticipated 2023 Medicare Physician Fee Schedule Proposed Rule from CMS has arrived! More detailed analyses from the Nixon Gwilt Law team will follow, but in the meantime, here are our top takeaways from the 2023 Proposed Rule.

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Medicare Physician Fee ScheduleCarrie Nixon, Rebecca Gwilt, Kaitlyn O'Connor, and Casey Papp2023 MPFS, MPFS, medicare, reimbursement, rpm, rtm, ccm, telehealth, Remote Patient Monitoring, remote physiological monitoring, Chronic Care Management, telebehavioral health, telemental health, CMS
Telehealth in the 2022 Medicare Physician Fee Schedule: Audio-Only Telehealth for Mental Health Made Permanent, and CMS Punts on Remote Direct Supervision
Telehealth in the 2022 Medicare Physician Fee Schedule: Audio-Only Telehealth for Mental Health Made Permanent, and CMS Punts on Remote Direct Supervision

On November 2, 2021, the Centers for Medicare and Medicaid Services (“CMS”) finalized the Medicare Physician Fee Schedule for Calendar Year 2022 (the “Final 2022 MPFS” or the “Final Rule”). As we noted in our July article discussing the Proposed 2022 MPFS, CMS made some significant proposed changes to allow for audio-only telehealth in some limited circumstances. In addition, the agency also proposed to enable remote “direct supervision,” which would allow practitioners to supervise clinical staff billing incident to their services as long as they could be available by audio/video communication as necessary.

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Telehealth, Medicare Physician Fee ScheduleRebecca GwiltTelemedicine, telementalhealth, 2022 Medicare Physician Fee Schedule, 2022, MPFS, Medicare, telemedicine, CMS, 99441, 99442, 99443, CPT, 93797, 93798, G0422, G0423, G2252
[video] Digital Health Innovators: Does your solution qualify as Software as a Medical Device (SaMD)?
[video] Digital Health Innovators: Does your solution qualify as Software as a Medical Device (SaMD)?

If you’re in the Remote Patient Monitoring (RPM) or Remote Therapeutic Monitoring (RTM) space, then you’ll want to understand the criteria and opportunities for qualifying as Software as a Medical Device (SaMD)

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Digital Therapeutics/SaMDKaitlyn O'ConnorRPM, RTM, SaMD, FDA, Life Sciences and Biotech, Tommy Miller, Kaitlyn O'Connor, CMS, Remote Therapeutic Monitoring, Remote Monitoring, Remote Patient Monitoring, software as a medical device
Remote Therapeutic Monitoring in the 2022 MPFS: How CMS Can (and Should) Get it Right
Remote Therapeutic Monitoring in the 2022 MPFS: How CMS Can (and Should) Get it Right

This is our take on the approach CMS should follow in improving and finalizing the RTM codes and associated reimbursement that improve patient outcomes and lower the overall cost of care. It is based on our extensive work with remote patient monitoring and care management digital health companies along with the physician practices who use the existing care management codes – including Remote Patient Monitoring (“RPM”), Chronic Care Management, Principal Care Management, and Behavioral Health Integration.

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Remote MonitoringCarrie Nixon2022 Medicare Physician Fee Schedule, Remote Therapeutic Monitoring, remote patient monitoring, Remote Monitoring, virtual care, RPM, RTM, MPFS, 2022, proposed rule, proposed medicare physician fee schedule, medicare physician fee schedule, CMS
What is a Value-Based Enterprise? New Opportunities for Digital Health and Healthcare Innovation
What is a Value-Based Enterprise? New Opportunities for Digital Health and Healthcare Innovation

Dramatic changes to the Anti-Kickback Statute and the Stark Physician Self-Referral Law regulations present an unprecedented opportunity for healthcare providers and digital health companies to create new business arrangements that align incentives around care coordination and patient engagement. Such arrangements are the foundation of the Value-Based Enterprise.

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Value-Based Care ModelsCarrie NixonDigital Health, fraud and abuse, AKS, AKS Safe Harbor, Anti-Kickback Statue, Stark Law, Stark, CMS, regulations, remote patient monitoring, OIG
Discover how six important additions and amendments to the physician self-referral law ("Stark") could create opportunities to grow your healthcare business in 2021
Discover how six important additions and amendments to the physician self-referral law ("Stark") could create opportunities to grow your healthcare business in 2021

A Final Rule published by CMS makes several important changes to the Stark Law that will be a boon for physicians eager to more closely coordinate with other providers to (1) better manage patient care and (2) to participate in the shift to value-based reimbursement.

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Corporate Healthcare LawRebecca GwiltStark Law, Stark, Digital Health, telemedicine, data analytics, innovation, CMS, healthcare innovation, healthcare attorney, healthcare lawyer, fee for value, value-based care, RPM, fraud and abuse, AKS, Safe Harbor, Rebecca Gwilt
Remote Patient Monitoring in the 2021 Medicare Physician Fee Schedule: The good, the bad, and the ugly
Remote Patient Monitoring in the 2021 Medicare Physician Fee Schedule: The good, the bad, and the ugly

On December 1, 2020, the Centers for Medicare and Medicaid Services (“CMS”) released its Final Medicare Physician Fee Schedule for 2021 (the “Final 2021 MPFS”), revising payment policies for services provided to Medicare beneficiaries by medical practitioners. These policies will take effect on January 1, 2021. Read on for insights from Team NGL.

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Remote Monitoring, Medicare Physician Fee ScheduleCarrie Nixon and Kaitlyn O'Connor2021 MPFS, Digital Health, Telehealth, Telemedicine, Remote Patient Monitoring, RPM, CMS, Medicare, regulations, 2021 Medicare Physician Fee Schedule, Carrie Nixon, Kaitlyn O'Connor
Behavioral Health Integration Under the 2021 Medicare Physician Fee Schedule Proposed Rule
Behavioral Health Integration Under the 2021 Medicare Physician Fee Schedule Proposed Rule

On Monday, August 3, 2020, the Centers for Medicare & Medicaid Services (“CMS”) released the 2021 Medicare Physician Fee Schedule Proposed Rule (the “Proposed Rule”). The 2021 Proposed Rule includes a new code under the Behavioral Health Integration (“BHI”) Collaborative Care Model (“CoCM”) that, if finalized, would offer reimbursement for a shorter increment of time than had previously been available under BHI.

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Behavioral Health, Medicare Physician Fee ScheduleKaitlyn O'Connorbehavioral health, CMS, MPFS, 2021 MPFS, RPM, Telehealth, Telemedicine, Kaitlyn O'Connor