Can CCM and RPM Be Billed Together?

Chronic Care Management (CCM) and Remote Patient Monitoring (RPM) are distinct healthcare services aimed at improving patient outcomes, particularly for individuals managing ongoing health conditions. CCM focuses on the comprehensive coordination of care for patients with multiple chronic diseases, while RPM involves the collection and analysis of physiological data from patients outside traditional clinical settings.

Understanding Chronic Care Management and Remote Patient Monitoring

Chronic Care Management (CCM) supports patients with two or more chronic conditions that are expected to last at least 12 months or until the patient’s death, and which place the patient at significant risk of acute exacerbation, decompensation, or functional decline. CCM provides proactive, non-face-to-face care coordination and management. Typical activities include developing and revising comprehensive care plans, managing medication, educating patients on their conditions, and coordinating care across various healthcare providers.

Remote Patient Monitoring (RPM) utilizes digital technologies to collect health data from patients in their homes or other remote locations and securely transmit this information to healthcare providers. RPM monitors specific physiological parameters, such as blood pressure, weight, or blood glucose. Activities involved in RPM include the initial setup and patient education on using monitoring devices, daily data transmission, and regular review of the collected data by clinical staff. RPM allows for timely interventions and adjustments to treatment plans based on real-time health trends.

Criteria for Concurrent Billing

Billing for both Chronic Care Management (CCM) and Remote Patient Monitoring (RPM) for the same patient within the same service period is permissible under specific conditions, as recognized by Medicare. Concurrent billing requires services under each program to be distinct, medically necessary, and without duplication of effort or time. This means that the time spent on CCM activities must be separate from the time spent on RPM activities, even if both are for the same patient in the same month. For instance, if 20 minutes are logged for CCM, those same minutes cannot be counted towards RPM services.

Patient consent is required for both CCM and RPM services. Before initiating either program, or both concurrently, the patient must provide informed consent. This consent should cover the availability of the services, potential cost-sharing responsibilities, and the patient’s right to stop the services at any time. For RPM, consent must be obtained before initiating services, and it should detail the purpose, data collection methods, privacy protections, and patient responsibilities. An initiating visit (in-person or via telehealth) is often required before starting CCM.

Healthcare providers must ensure that the scope of services for CCM and RPM remains separate when billed concurrently. While RPM data can inform the patient’s overall CCM care plan, activities and time for monitoring remote data must be clearly distinguishable from broader CCM care coordination. For example, a care coordinator discussing a patient’s overall medication adherence (CCM) is distinct from a clinical staff member reviewing transmitted blood pressure readings and communicating about device usage (RPM). This separation ensures compliance and avoids double-billing.

Billing Codes and Documentation

Concurrent billing for Chronic Care Management (CCM) and Remote Patient Monitoring (RPM) involves specific Current Procedural Terminology (CPT) codes and rigorous documentation. For CCM, CPT codes include 99490 for the initial 20 minutes of non-complex care coordination, with add-on code 99439 for additional 20-minute increments. Complex CCM services are reported with CPT code 99487 for the first 60 minutes, and 99489 for additional 30-minute increments. When a physician or other qualified healthcare professional personally provides at least 30 minutes of CCM, CPT code 99491 is used.

For Remote Patient Monitoring, CPT codes include 99453 for the initial setup of monitoring equipment and patient education. CPT code 99454 covers the supply of the device and daily recording or transmission of data, requiring at least 16 days of data transmission within a 30-day period for billing. CPT code 99457 is utilized for the first 20 minutes of treatment management services, which includes clinical staff or physician time, involving interactive communication with the patient or caregiver. Additional 20-minute increments of these management services are billed with CPT code 99458.

When billing CCM and RPM concurrently, appropriate modifiers, such as Modifier 25 or 59, may be necessary if services are provided on the same day as an Evaluation and Management (E/M) service to indicate that the CCM or RPM service was distinct and separately identifiable. Documentation is crucial for compliance and justification of medical necessity. This includes clear proof of patient consent for both CCM and RPM services. Detailed time logs for CCM services must be maintained, showing non-face-to-face clinical staff time spent on care coordination activities. For RPM, records of device provision, patient education on its use, and evidence of consistent data transmission for at least 16 days are required. Documentation must also clearly demonstrate that the services performed under CCM are separate from those under RPM, even if for the same patient in the same month, with distinct time entries for each.