Remote Patient Monitoring

In our last client update, Acadia outlined important liability insurance coverage issues related to telehealth services, as well as government efforts to help facilitate alternative means of providing patient care in light of the current pandemic.  The realities of the COVID 19 crisis extend beyond just checking in with patients when symptoms present. To help ensure ongoing care and treatment, physicians are exploring all patient care options, including remote patient monitoring (RPM). We outline the key aspects of RPM and the exposures of which to be aware.  

Technology: 

Remote monitoring technology has been around for many years, but it has improved considerably over the past several months.  Many platforms now integrate with both EHRs and billing systems. 

RPM can be used for a variety of diagnoses, such as diabetes and hypertension.  The technology itself will often impact which diagnoses can be effectively monitored remotely, so it is important to conduct due diligence.  

Cost: 

The cost to implement remote monitoring varies and can be structured in several ways.  Most platforms involve the installation of an app on a smart phone, which collects the data and transmits it to the physician office EMR.  If a medical practice’s existing EMR system already supports RPM, it may require a small additional monthly fee to add the service. If you need to engage a new company, payment can be in the form of an upfront fee, an ongoing fee, a percentage of revenue per patient use, or some combination of each. 

Reimbursement: 

The current pandemic has forced payors to upgrade payment reimbursement models to ensure that the use of telemedicine to treat patients is economically feasible.  CMS already expanded Medicare payment for RPM on January 1st 2020. CPT codes related to RPM include: 

  • Set-up fee (99453)
  • Monthly equipment fee (99454)
  • Treatment Management fees (99457)
  • Additional treatment fees (99458)

In addition to being an incremental revenue source in a FFS environment, effective RPM can improve care and reduce overall healthcare costs by preventing unnecessary ED visits and hospitalizations.  If successful, physicians participating in value-based care programs can thus realize additional value, while preventing underlying causes for lawsuits.     

Liability: 

As with any new service expansion, associated liability should be considered.  To mitigate RPM risk, practices should develop a clear and comprehensive informed consent process, clearly outlining the specific limitations on what the technology and care is intended to achieve.  Moreover, expectations should be set regarding how often patient information is reviewed, and how the communication process between patients and practices works.

If done well, remote patient monitoring could help reduce exposure to liability.  Identifying problems before they develop into serious complications can prevent adverse outcomes.  Mediums that improve communication (assuming HIPAA compliant), can foster improved physician-patient relationships and keep plaintiff attorneys out of the conversations. 

Conclusion: 

Disruptive times often prompt disruptive change.  Technology is being embraced like never before in healthcare, and the industry may never turn back.  Like telemedicine and other digital provider services, physician groups should also evaluate whether remote patient monitoring is appropriate. 

  

For more information on how your practice can implement remote patient monitoring, contact Brian Kern, Esq., Partner, Acadia Professional, at bkern@acadia.pro

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