Payment for Some Third-Party Remote Patient Monitoring at Risk in Proposed Medicare Fee Schedule
By Phil West

The proposed 2027 Medicare physician fee schedule would stop paying third-party vendors that provide remote patient monitoring – a change the Texas Medical Association warns could hinder many physician practices and create access to care issues, even as the Centers for Medicare & Medicaid Services (CMS) rolls out a new program built on similar technology.

Under the proposal, CMS would allow payment for remote physiologic monitoring or remote therapeutic monitoring – collectively, remote patient monitoring (RPM) – only when the services, including device supply or patient education and setup, are furnished by clinical staff directly employed by the physician or the physician’s practice. Contracting those services to third-party vendors would no longer qualify for payment.

RPM use surged between 2019 and 2022, per a U.S. Department of Health and Human Services Office of Inspector General fact sheet, but 43% of patients did not receive all three RPM components – patient education and setup, device supply, and treatment management.

In its proposed rule, CMS said that figure “rais[es] questions about whether the monitoring is being used as intended,” spurring the proposed changes. TMA argues the proposal overcorrects.

“Many physician practices lack the staffing and technical infrastructure necessary to administer these programs internally,” TMA wrote in its comments on the proposal. “CMS should address legitimate program-integrity concerns without restricting physicians’ ability to use qualified third-party vendors or limiting patient access to remote monitoring services.”

Jason Acevedo, MD, a past member of TMA’s Council on Socioeconomics, cautions that restricting Medicare payment for physicians using a third-party vendor for the supply and setup of RPM devices would adversely impact patients as well as physicians.

“These third-party vendors are so valuable because most doctors’ offices are already spread pretty thin,” the Abilene otolaryngologist said. “Unless you have a pretty sizable clinic, it’s just hard to have the economy of scale to do this [work] in-house.”

“If the third-party vendors go away, I think a lot of physician offices will just quit participating [in RPM], and then the patients lose access to it,” he predicted.

In its comment letter, TMA also noted that CMS is simultaneously encouraging remote monitoring through its Advancing Chronic Care with Effective, Scalable Solutions (ACCESS) Model, launched in July. ACCESS targets four chronic conditions that CMS says affect more than two-thirds of Medicare patients, deploying U.S. Food and Drug Administration-authorized devices to monitor sleep, heart rate, and movement as part an overall care plan.

TMA argues the proposed fee schedule would restrict contracted clinical staff and change payment for monitoring services at the same moment ACCESS is pushing physicians toward exactly those tools.

“We’re trying to decrease the cost of care, and one way you do it is you keep patients out of the high-cost centers, the ERs, and the hospitals, and RPM is a tool to do that,” Dr. Acevedo said. “So, they’re on one hand saying use these technologies and help us decrease the cost of care, but on the other … restrict[ing] the way you do that.”

Learn more about technology and patient safety via TMA’s online resource page.