Introduction
In 2024, the AMA published an article on the Future of Health and the Emerging Landscape of Augmented Intelligence in Health Care. [1] The article noted that:
There is a growing enthusiasm for augmented intelligence in healthcare, with 65% of physicians recognizing its potential benefits.
In 2023, however, only 38% of physicians were using AI, primarily for documentation, translation services, and diagnostic assistance; 62% of physicians were not using AI.
A significant 56% of physicians believe AI's strength lies in automating administrative tasks. The greatest excitement surrounds AI tools that can alleviate administrative burdens, particularly in documentation (54%) and prior authorization (48%).
This optimism is tempered by concerns, with 41% of physicians expressing both excitement and concern.
The promise of AI in supporting diagnosis (72%) and workflow (69%) is highly anticipated, yet there are worries about its impact on the patient-physician relationship (39%) and patient privacy (41%).
Looking ahead, physicians plan to implement AI in generating patient messages, chart summaries, and predicting demand and workforce needs within the next five years.
For widespread adoption, physicians require resources and support, emphasizing data privacy assurances, protection from liability for AI model errors, and malpractice insurance coverage.
Clinical evidence is seen as the most valuable resource by 35% of respondents, highlighting the need for robust data to support AI integration in healthcare.
In 2023, the AI use cases across medical specialties were:
· Creating discharge instructions and/or progress notes – 14%
· Documenting billing codes, medical charts, or visit notes – 13%
· Translation services – 11%
· Assistive diagnosis – 11%
· Patient-facing chatbot – 8%
· Creation of chart summaries – 8%
· Create recommendations and self-care engagement – 8%
· Predict health risks, quality gaps, outcomes – 8%
· Automate pre-authorization – 7%
· Summarize medical research – 6%
· Surgical simulations and guidance – 5%
· Generate draft responses to patient portal messages – 5%
· Analyze patient-generated wearable and remote patient monitoring data – 4%
· Predict demand and staffing needs – 3%
· Triage and case prioritization support – 3%
U.S. FDA-Approved AI Medical Devices
As of August 7, 2024. The U.S. FDA has authorized 950 Artificial Intelligence and Machine Learning (AI/ML)-Enabled Medical Devices, approved for clinical AI applications. [2]
The AI applications which are tailored to radiology make up over 70%, followed by cardiology then a distant third neurology.
The Centers for Medicare & Medicaid Services (CMS) and private insurance reimbursement for clinical AI applications has not kept pace with the rapidly evolving AI technology.
AMA CPT Editorial Panel AI Taxonomy
In 2019, the AMA CPT Editorial Panel established the first category of Current Procedural Terminology (CPT®) code for an AI product, which is distinct from payment. [3]
In 2020, Medicare approved reimbursement of its first CPT code and New Technology Add-On Payment (NTAP) for AI devices.
In 2021, the AMA’s CPT® Editorial Panel [4] published Appendix S - “Artificial Intelligence Taxonomy for Medical Services and Procedures”, classifying into three ordered categories various artificial intelligence (AI) applications for medical services and procedures – namely, assistive, augmentative, and autonomous.
Appendix S went into effect on January 1, 2022. It provided guidance on coding for AI applications. It was not published in the 2022 CPT® code book. It was first published in the 2023 CPT® code book.
The AMA taxonomy was based on the clinical procedure or service provided to the patient and the work performed by the AI machine on behalf of the physician or other qualified healthcare professional (QHP). The three categories are:
“Assistive” denotes work performed by the AI machine that detects clinically relevant data without analysis or generated conclusions. It requires an interpretation and report by the physician or other qualified health care professional (QHP).
“Augmentative” means work performed by the AI machine that analyzes and/or quantifies data to yield clinically meaningful output. It also requires an interpretation and report by the physician or other QHP.
“Autonomous” comprises AI machines that automatically interpret and analyze data and independently generate clinically meaningful conclusions without concurrent physician or other QHP involvement. The machine algorithm may or may not include acquisition, preparation, and/or data transmission.
Because autonomous AI can operate nearly free of human interaction, the AMA CPT® Editorial Panel felt the need to establish different levels of autonomy.
The Appendix S guidelines state that there is not a certain product, service, or procedure where AI is necessary to describe the intended medical use. Consequently, the appendix does not list specific codes for which the guidelines could apply.
The AMA taxonomy defines the relationship between the work completed by the machine and that done by a human. It also shows the relevance to AI.
In 2022, the AMA’s CPT Editorial Panel created new CPT® codes for remotely monitoring musculoskeletal patients, and Medicare approved coverage and payment for these services. Since then, physicians and qualified healthcare professionals (PAs, Nurse Practitioners, CRNAs and Nurses) have been reimbursed for remotely monitoring their patients from home.
In September 2024, the AMA [5] released 420 updates to its CPT code. They take effect on January 1, 2025. They include the following AI codes:
1. Remote therapeutic monitoring (RTM) services were updated.
Code 98975 includes digital therapeutic intervention.
Codes 98976-98978 include device supply for data access or data transmissions to support RTM patients.
2. Seven category III codes were established for AI augmentative data analysis involved in:
Electrocardiogram measurements (0902T and 0932T),
Medical chest imaging (0877T-0880T), and
Image-guided prostate biopsy (0898T).
CPT Codes for Telehealth and RPM Billing - CMS Guidelines [6]
1. Telehealth/Telemedicine Visits
99202 – 99205: Office or other outpatient visits.
99211 – 99215: Office or other outpatient visits.
G0425 – G0427: Consultations, emergency department, or initial inpatient.
2. Virtual Check-Ins for Providers who can bill independently
G2010: Remote evaluation of recorded video and/or images submitted by an established patient with follow-up within 24 business hours.
G2012: 5-10 minutes of technology-based communication by a physician or other qualified health care professional who can report evaluation and management services not originating from a related E/M service provided.
G2252: 11-20 minutes of technology-based communication by a physician or other qualified health care professional who can report evaluation and management services not originating from a related E/M service provided.
3. Virtual Check-Ins (For providers who cannot independently bill for E/M services)
G2250: Remote assessment of recorded video and/or images submitted by an established patient with follow-up within 24 business hours.
G2251: 5-10 minutes of technology-based communication by a qualified health care professional.
4. Virtual Visit
99421 – 99423: Online digital evaluation and management service, for up to 7 days, a cumulative time during the 7 days by provider.
G2061 – G2063: Online assessment by qualified non-physician healthcare professional.
5. Telephone Services
99441 – 99443: Evaluation and management by a physician or other qualified health care professional provided to a patient, parent, or guardian not originating from a related E/M service provided.
6. Interprofessional Telephone/Internet/Electronic Health Record Consultation
99446 – 99449: Assessment and management service provided by a consultative physician.
99451: Assessment and management service provided by a consultative physician, 5 minutes or more of medical consultative time.
99452: Referral service provided by a treating/ requesting physician or other qualified health care professional, 30 minutes.
7. Telemedicine Services
G0406 – G0408: Follow-up inpatient consultation via telehealth
G0425 – G0427: Telehealth consultation, emergency department
G0508, G0509: Telehealth consultation, critical care
8. RPM (Remote Patient Monitoring) and RPM CPT Codes
RPM services require an established physician-patient relationship.
RPM is used to monitor patients with acute or chronic conditions that require
close observation.
RPM services focus on the collection, analysis, and interpretation of physiological data from patients, such as vital signs - heart rate, blood pressure, and oxygen saturation levels.
RPM is used for patients that require continuous monitoring of physiological data such as heart rate, blood pressure, and oxygen saturation levels. For example,
Patients with diabetes might use RPM to monitor their blood glucose levels remotely.
Patients with congestive heart failure can use RPM for heart rate and oxygen saturation levels.
The billable CPT codes for providing RPM services to patients, as well for staff time spent monitoring these patients include:
99091 - is used for the time spent by a physician or qualified health professional in reviewing the data and communicating with the patient. 30 minutes.
99453 - covers the initial device setup and educating the patient on how to use the RPM device.
99454 - covers the subsequent monitoring service provided by a physician or other qualified health professional (QHCP). It includes supply of devices and collection, transmission, and summary of services.
99457 - is for the collection, analysis, and interpretation of physiologic data. First 20 minutes of remote physiologic monitoring, collection, analysis, and interpretation by clinical staff/ Physician/QHCP.
99458 - is an additional 20 minutes of remote physiologic monitoring by clinical staff/Physician/QHCP.
G0511 - The 2024 physician fee schedule added general care management code for rural health clinic or federally qualified health center (RHC of FQHC) only to bill for RPM or RTM (not both).
Sample First Month RPM Billing
RPM CPT CODE REIMBURSEMENT
• 99091 $ 52.71
• 99453 $ 19.65
• 99454 $ 46.83
• 99457 $ 48.14
• 99458 $ 38.64
• G0511 $ 72.98
• TOTAL $ 205.97 - $ 278.95
RTM (Remote Therapeutic Monitoring)
Unlike RPM, RTM does not require an established physician-patient relationship.
But it is expected that a treatment plan has been established by the provider before the monitoring begins.
RTM it can be used by a broader range of medical professionals.
It is used for patients who require monitoring of non-physiological data, such as medication adherence, therapy adherence, and other therapeutic interventions.
RTM is useful for patients who need to track their compliance with the treatment plans. For example, patients with a mental health condition might use RTM to monitor their adherence to medication and therapy schedules.
The CPT codes for RTM which are billable by practitioners who are not eligible to bill E/M services codes (unlike providers who are eligible to bill E/M codes for RPM services) include:
98975 – is for the initial set up and patient education.
98976 - 30 days-supply of device(s) for monitoring respiratory system; it is for the collection and interpretation of non-physiological respiratory data.
98977 – is for 30 days-supply of device(s) for monitoring musculoskeletal system; it is for the collection and interpretation of non-physiological musculoskeletal data.
98980 - is for the first 20 minutes of monitoring or treatment management service.
98981 - is for an additional 20 minutes of monitoring or treatment management service.
CCM (Chronic Care Management)
CCM is for patients with:
Two or more chronic medical conditions.
Expected to persist for more than 12 months following diagnosis; and
Place the patient at an increased risk for hospitalization.
CCM involves:
Coordination of care and support for the patients.
Includes regular communication with patients to assist with prescription refills, adherence to care plans, and other support services.
For example, a patient with two conditions, heart disease and diabetes, might use CCM to manage their chronic conditions effectively.
The CPT Codes for CCM include:
99437 - is used to bill for subsequent care provided by a physician or non-physician practitioner (NPP) that lasts for 30 minutes. This care is typically provided in a chronic care management context and is billed in addition to the initial care provided.
99439 - is used to bill for subsequent care provided by clinical staff, such as nurses or medical assistants, that lasts for 20 minutes. This care is also typically provided in a chronic care management context and is billed in addition to the initial care provided.
99487 - is used to bill for a minimum of 60 cumulative minutes of non-face-to-face consultation time over a 30-day period. This time is spent establishing or monitoring a care plan for a patient. It is used in the context of complex chronic care management.
99489 - is used to bill for every additional 30 minutes of non-face-to-face consultation time beyond the initial 60 minutes billed under 99487. This is also used in the context of complex chronic care management.
99490 - is used to bill for a minimum of 20 minutes of non-face-to-face consultation time spent monitoring the care plan for a patient. This code is used when the consultation time does not meet the threshold for 99487.
99491 - is used to bill for the initial 30 minutes of care provided personally by a physician or non-physician practitioner. This care is typically provided in a chronic care management context and is billed as the first unit of service.
99492 - is used to bill for every additional 30 minutes of care provided by a physician or non-physician practitioner beyond the initial 30 minutes billed under 99491. This care is also typically provided in a chronic care management context.
CPT Codes fort AI Medical Procedures:
CPT Code (s) Condition or Medical AI Procedure
1) 0501T–0504T Coronary artery disease
2) 92229 Diabetic retinopathy
3) 0623T–0626T Coronary atherosclerosis
4) 0648T–0649T Liver MRI
5) 0697T–0698T Multiorgan MRI
6) 0689T–0690T Breast ultrasound
7) 0764T–0765T ECG cardiac dysfunction
8) 0716T Cardiac acoustic waveform recording
9) 0723T–0724T Quantitative MR cholangiopancreatography
10) 0777T Epidural infusion
11) 0721T–0722T Quantitative CT tissue characterization
12) 0740T–0741T Autonomous insulin dosage
13) 0691T CT vertebral fracture assessment
14) 0710T–0713T Noninvasive arterial plaque analysis
15) 0731T Facial phenotype analysis
16) 0749T X-ray bone density
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