By Matt Fisher, General Counsel, Carium
Twitter: @matt_r_fisher
Twitter: @cariumcares
Host of Healthcare de Jure – #HCdeJure
Remote patient monitoring (RPM) is a form of telehealth receiving increasing attention and focus as a means of improving overall patient health and engagement. As a starting point though, what is remote patient monitoring? RPM is often defined as the remote collection and transmission of patient data for analysis and evaluation by a care team, which data is used to develop and manage a treatment plan connected to a chronic and/or acute condition.
RPM Requirements from Medicare
Medicare is currently the main source of reimbursement for provision of RPM. Since Medicare is the primary payor, understanding the high level requirements imposed by Medicare is instructive before diving into the benefits that can be derived from RPM. When seeking separate reimbursement for RPM, Medicare (or really the Centers for Medicare and Medicaid Services) look for the following elements (it should be noted that this is not a comprehensive listing of CMS’s requirements):
- RPM needs to be initiated by a physician or non-physician practitioner (really someone who can bill Medicare for their services);
- The patient must be an established patient of the clinician;
- RPM can be used to address a chronic or acute condition (the expansion to acute conditions is an important recent change);
- RPM must be reasonable and necessary for the treatment of the patient’s illness or injury;
- Data must be collected and then transmitted automatically (no manual entry by the patient is permitted);
- Data must be collected for at least 16 days in each 30 day period (this requirement was relaxed by COVID-19 related waivers and is a controversial component of CMS’s RPM requirements); and
- Interactions or evaluations of data must occur in 20 minute cumulative chunks.
Leaving aside the means of meeting all of the requirements, the underlying context of RPM is to encourage ongoing engagement and connection between the patient and the care team while also gathering more data about the patient from their daily lives. The aim of RPM can then be seen as trying to get patients to an overall healthier state since it is possible to see trends or warning signs of an issue more quickly while also adjusting treatment.
Why RPM?
The appeal of RPM can be seen through the lens of both the patient and the care team. From the patient perspective it encourages and enables individuals to see almost continuous feedback about certain metrics of their health. The feedback can result in better self-awareness of how different actions or choices can influence the factors being monitored. Additionally, the opportunity to see one’s own data can drive self-motivation for lifestyle changes. One individual’s journey offers an example of how that person used the RPM style driven tracking of data as a way to advocate for their own care as well as informing care teams that were not directly involved with the primary issue that the individual was facing or as care was transitioning.
From the care team perspective, increasing engagement and understanding of their patients is a clear reason to pursue RPM. The time with a patient in the clinician’s office is very limited as should be well known at this point in time. If time is constrained, then finding means to more easily interact with and understand what is happening with patients should be an easy decision. Further, RPM does not need to be heavy touch either as many of the process can be automated or streamlined to involve many members of the care team. For example, when a care team member reviews the transmitted data and can see a warning sign of a potential issue coming, the care team can proactively reach out to the patient to adjust the treatment plan or initiate a virtual visit. Either option creates the chance to engage with the patient and prevent a more serious concern from arising, which means better health and cost savings.
RPM as a Stepping Stone
The descriptions of how RPM can change behaviors imply that RPM is a good stepping stone to value based care. The general aims of value based care are to improve health outcomes through greater efficiency while reducing the cost of delivering care. Data are mounting that RPM can check all of those boxes by facilitating proactive care that introduces earlier interventions with patients, which in turn means reducing the severity of an issue. Reduction in severity typically means the acuity of the potential issue is reduced and that translates to fewer resources in the healthcare system being accessed along with the individual getting back to better health more quickly.
Considering the attention that value based care models received as a means of insulating healthcare organizations from the financial strains that resulted from the COVID-19 pandemic, RPM is a good way to ease into a different style of care delivery. The more regular engagement with patients that RPM encourages (or requires depending on the point of view) establishes new workflows for care teams. The new workflows can then be translated to other circumstances as well as used as a testing ground to enhance efficiencies that can fuel value based care.
At the same time, instantaneous success should not be expected. Some amount of trial and error will always occur because reality makes it impossible to expect that all changes will work well immediately. That is another benefit of using RPM as a transition from traditional fee for service to value based care. Since RPM is reimbursable as a distinct service, experience can be developed of how to most effectively engage with patients and respond t the incoming information. That experience can then be translated to value based care models where the ability to be reimbursed for a distinct service is less important.
Expanding Scope of RPM
The expanding scope of RPM is where the support for the transition to value based care can arguably be seen most readily. As noted in the high level description of RPM, either chronic or acute conditions can qualify for RPM coverage. That means RPM can potentially be quite episodic or ongoing and driven by the needs of the particular patient. Additionally, since utilization of RPM is largely driven by the determination of a physician or other qualified clinician, there is no predetermined scope of issues or conditions for when RPM can be used. Instead, professional judgment helps to drive the use. For example, RPM has been or is currently used for a wide range of cases such as post-cardiac surgery, diabetes, blood pressure, sleep apnea, and COVID-19. The potential applications are arguably limited only by what conditions can be improved through the collection of remote data and how those interactions can occur.
Since the inclusion of acute conditions is still new, the full impact has yet to be determined. However, clinicians are starting to see the opportunities and enterprising clinicians are trying to be the first into different areas.
Onward
With all of the potential benefits for RPM, its expansion within the scope of care delivery should be relatively clear. More opportunities will likely arise, especially if value based care becomes more entrenched. As suggested, RPM could actually be a driver for more value based care models because of the way that it prepares and enhances operations in that realm. Ultimately, the key is to improve overall health and wellbeing for individuals, which means collaboration and coordination among all parties (that must include the patients).
This article was originally published on The Pulse blog and is republished here with permission.