Remote Monitoring is here to stay
The horse is out of the barn, the train has left the station, that ship has sailed. Whichever idiom you prefer, remote monitoring is the standard of care for patients with implantable cardiac devices for the simple fact that remote monitoring affects the outcomes measures that matter the most: morbidity and mortality. As patient care continues to move beyond the confines of the physician office, practices need to be compensated commensurate with the time commitments required to offer a continuous level of care. One month ago, I published a link for interested persons to submit an open comment regarding the proposed payment reductions for remote monitoring contained within the 2018 Proposed Physician Fee schedule; below is my submission to the Federal Register:
I am expressing my deep concern over the proposed changes to AICD monitoring reimbursement, particularly for the remote monitoring code 93295. The drastic reduction in RVUs for 93295 are wholly inconsistent with the time requirements and focus on patient care required to review remote monitoring reports. The time and dedication required to care for patients remotely is not a series of singular-occurrence events reimbursed by this professional component but rather is reflective of the continuous monitoring and care of these patients. The inherent value of this continuous remote monitoring is demonstrated by published effects upon both the morbidity and mortality in this advanced cardiac disease patient population. The professional fee reimbursement, which you are proposing to decrease by 42.64%, drastically undermines the ability of practitioners like myself to institute and maintain the highly beneficial remote monitoring care of these patients. As I can only hope you are aware, the 93295-professional fee is billable only once but every 91 days but encompasses the professional services in caring for these patients via every transmission attended to for the ENTIRE 90-day period, hence continuous. The personnel power and infrastructure needed to accomplish this task is gargantuan on both the technical and professional levels. Every report reviewed during this 90-day period requires us to review:
1. The voluminous data included in the remote transmission, which presents data not only referencing the functionality of the device but also the clinical status of the patient themselves.
2. The patient’s individual medical records, so that we may orient ourselves to the individual clinical conditions and co-morbidities unique to each patient, which affects our responses to the remote data which we are continuously reviewing.
As the paradigm in patient care moves to continuous care of the patient beyond the walls of the clinical practice, I am mystified that interventions which are successful, like 93295, are targeted for cuts so drastic as to potentially reverse the entire compendium of clinical progress that remote monitoring has afforded to this high morbidity, high mortality and high healthcare utilization group of healthcare beneficiaries. In lieu of shifting the reimbursement for the remote monitoring codes away from higher reimbursement, based on the true time and effort expended in the continuous review of data during the 90-day coverage period, all of the remote monitoring reimbursements frankly need to be adjusted and more congruent with the current 93295 remuneration, not vice versa.
I hope you sincerely consider my comments and defer the proposed remote monitoring reductions, which I believe directly undermines, rather than advances, the care of this patient population.