In the midst of uncertain times, one fact remains crystal clear: the path to revolutionizing
healthcare in rural areas demands innovation, adaptability, and an unwavering commitment to
enhancing patient well-being. As Rural Health Clinics (RHCs) embark on this transformative
journey, their resilience and ingenuity are poised to shape the future of rural healthcare,
ensuring that every patient can access top-quality care.
The sustained use of telehealth following the pandemic underscores the imperative for RHCs to
embrace remote care solutions as a norm and a necessity. However, RHCs face unique
challenges in the healthcare landscape, such as sicker patient populations, limited resources,
workforce shortages, and geographic isolation demands innovative solutions. While CMS has
made significant progress in distinguishing Chronic Care Management (CCM) services, issues
related to equitable access persist. Notably, RHCs are unable to bill for RPM codes. Presently,
these services are considered part of the comprehensive rate, encompassing the offerings of
these facilities' programs, and limited to billing one G0511 code each month, regardless of the
number of care management services provided.
The Proposed Rule for 2024 sheds light on the integration of RPM into the existing remote care
framework. Under the proposed changes, the G0511 code for 2024 is set to cover various
services, including Chronic Care Management (CCM), Principal Care Management (PCM),
Behavioral Health Integration (BHI), Chronic Pain Management (CPM), Remote Therapeutic
Monitoring (RTM), and Remote Physiological Monitoring (RPM). Although this expansion is
promising, it's worth noting that CMS suggests a slight decrease in the current reimbursement
rate for G0511, which currently stands at $77.94.
With a reduced rate of $72.98, the implications are significant. While the primary driver for a
provider's decision-making should be medical necessity rather than financial constraints, this
proposal places RHCs in a delicate position if they can't provide the appropriate bundle of
services under G0511. Unlike non-RHC counterparts, RHCs must balance financial viability with
the delivery of high-quality care.
In response to these challenges, RHCs must adopt innovative solutions. One strategic approach
is to integrate RPM with existing or newly established CCM programs. This blend not only
addresses billing limitations but also encourages meaningful patient engagement. By offering
comprehensive support, including clinical health coaching and connected devices, RHCs can
improve patient interactions, resulting in higher adoption rates. Enrolling in both programs
streamlines the process, maximizing the benefits of both CCM and RPM. This harmonious
integration not only captures existing work but also significantly boosts annual revenue, making
it a financially viable option for RHCs.
As RHCs stand on the brink of change, the 2024 Proposed Rule introduces unique nuances for
rural health. For example, under this new proposal, both codes tied to a calendar month (e.g.,
CCM) and those associated with a rolling 30-day period (e.g., RPM device) would fall under the
single-unit-per-month G0511 code. The convergence of billing codes presents a strategic
dilemma: should RHCs prioritize device readings or care management time? This decision
hinges on understanding the needs of the patient population and requires adaptability,
proactive strategies, and ongoing advocacy.
Proactively navigating this ambiguity is crucial to harness the full potential of remote care
solutions for RHCs, paving the way for a more connected and patient-centric healthcare system.
Fortunately, rural health providers have access to partners well-versed in rural healthcare,
ready to support the conversation.