May clinical staff provide Remote Physiologic Monitoring (RPM) services under general supervision?


Yes. In the CY2022 Medicare Physician Fee Schedule (MPFS) final rule, RPM services, including but not limited to CPT/HCPCS codes 99453 and 99454, and related beneficiary consent obtained by auxiliary personnel (i.e., clinical staff) requires the general supervision of the billing practitioner. General supervision means that the procedure is furnished under the physician’s overall direction and control, but that the physician’s presence is not required during the performance of the procedure.

Moreover, as specified in the interim final rule with comment period (IFC), during the COVID-19 Public Health Emergency (PHE), when physicians and other healthcare professionals are faced with challenges regarding potential exposure risks for themselves or their patients, the direct supervision requirement that applies for most other services that are furnished incident to a physician or other practitioner’s services may be met virtually through audio/video real-time communications technology.

This question was answered in our Coding Essentials for RT/Pulmonary Function. For more hot topics relating to respiratory services, please visit our store or call us at 1.800.252.1578, ext. 2.


CPT® copyright 2021 American Medical Association (AMA). All rights reserved.

Fee schedules, relative value units, conversion factors and/or related components are not assigned by the AMA, are not part of CPT, and the AMA is not recommending their use. The AMA does not directly or indirectly practice medicine or dispense medical services. The AMA assumes no liability for data contained or not contained herein.

CPT is a registered trademark of the American Medical Association.