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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

  • work Practice Area

    Health

Date & Time
  • event Date

    Wednesday, February 15, 2023

  • schedule Time

    1:00 p.m. ET./10:00 a.m. PT

  • timer Program Length

    90 minutes

Credit Information

  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.

$297.00
CLE
ALL

This CLE course will guide healthcare counsel on remote patient monitoring. The panel will examine reimbursement standards for remote physiologic monitoring (RPM) and remote therapeutic monitoring (RTM). The panel will also address privacy, security, and compliance challenges of remote patient monitoring.

Faculty

Rick L. Hindmand
Counsel
Mcdonald Hopkins LLC

Mr. Hindman focuses his practice on healthcare regulatory, data privacy, cybersecurity, corporate, and transactional matters. He represents physicians and other healthcare providers and organizations in structuring group practices, joint ventures, medical device companies, as well as physician/hospital alignment strategies and involvement in accountable care organizations (ACOs). He also assits healthcare providers and businesses with potential compliance challenges, including compliance with the Stark physician self-referral law, federal and state anti-kickback laws, and corporate practice and fee-splitting restrictions.

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Iliana L. Peters
Shareholder
Polsinelli

Ms. Peters is recognized by the healthcare industry as a preeminent thinker and speaker on data privacy and security, particularly with regard to HIPAA, the HITECH Act, the 21st Century Cures Act, the Genetic Information Nondiscrimination Act (GINA), the Privacy Act, and emerging cyber threats to health data. For over a decade, Ms. Peters both developed health information privacy and security policy, including on emerging technologies and cyber threats, for the Department of Health and Human Services, and enforced HIPAA regulations through spearheading multi-million-dollar settlement agreements and civil money penalties pursuant to HIPAA. She also focused on training individuals in both the private and public sector, including compliance investigators, auditors, and State Attorneys General, on HIPAA regulations and policy, and on good data privacy and security practices. As a CISSP, Ms. Peters works hard to bridge the gap between legal requirements for the security of health data and security industry best practices, so that clients can better understand data security issues and jargon.

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Description

Since Medicare began paying for RPM services in 2018 the Centers for Medicare & Medicaid Services (CMS) has expanded RPM coverage with additional codes and guidance, and in 2022 began covering RTM. On Nov. 1, 2022, CMS released the CY2023 final rule for services reimbursed under the Medicare Physician Fee Schedule (MPFS). The final rule changes to Medicare Part B professional payment policies and rates for 2023. The final rule allows payment under new RTM device codes for cognitive behavioral therapy and loosens supervision standards for RTM. CMS did not finalize its proposal to replace RTM codes with new G codes, which CMS recognized was creating confusion.

CMS has revised Medicare payment policies for remote patient monitoring so that RPM and RTM can be provided "incident to" under general supervision, thereby making it less burdensome for providers to furnish remote patient monitoring services.

Those utilizing RPM or RTM must ensure they comply with licensure, scope of practice, coding and related requirements to be eligible for reimbursement.

Further, patient monitoring has historically been set up in healthcare facilities, while RPM and the associated monitoring equipment are deployed in the patient's home. This difference presents risks, including to data privacy and security. Among other issues, wireless networks, platforms, and devices are susceptible to being hacked, allowing access to sensitive health information, and many questions have arisen about considerations for patients' privacy and the security of their information.

As healthcare provider organizations seek to invest in and utilize RPM or RTM solutions, particularly as patients have become accustomed to remote care during the pandemic, they should consider the risks and compliance challenges to RPM and understand the reimbursement landscape.

Listen as our authoritative panel of healthcare attorneys examines reimbursement and how recent changes impact the landscape for remote patient monitoring. The panel will also address the challenges of remote patient monitoring, such as privacy and security, as well as related compliance considerations.

Outline

  1. Reimbursement standards
    1. RPM
    2. RTM
  2. RPM and RTM contracting, collaboration, and supervision structures
  3. Risks
    1. Privacy
    2. Security
    3. Payor audits
    4. Fraud and abuse
  4. Compliance considerations
    1. Professional qualifications for supervision and billing
    2. Self-referral and anti-kickback
    3. Payment and regulatory flexibilities during the COVID-19 PHE
    4. State and federal data privacy and security requirements

Benefits

The panel will review these and other key issues:

  • How have reimbursement standards for RTM changed under the 2023 MPFS?
  • What are the key distinctions between the RTM and RTM billing codes?
  • How can healthcare providers collaborate with clinical staffing companies, IT, and medical device vendors and others to furnish remote patient monitoring?
  • What are the privacy and security risks associated with remote patient monitoring?
  • How should HIPAA covered entities, business associates, and others implement such devices while protecting data privacy and security?
  • What steps should healthcare providers take to ensure compliance with RPM and RTM requirements?