iRhythm Comments on CMS 2021 Proposed Physician Fee Schedule

iRhythm Technologies, Inc. (NASDAQ: IRTC), a leading digital health care solutions company focused on the advancement of cardiac care, commented on the recently released Centers for Medicare and Medicaid Services (“CMS”) Calendar Year 2021 Medicare Physician Fee Schedule Proposed Rule (the “Proposed Rule”). The Proposed Rule was released on August 3, 2020 and updates payment policies, payment rates, and other provisions for services furnished under the Medicare Physician Fee Schedule (“PFS”) on or after January 1, 2021. The Proposed Rule release is followed by a public comment period which will culminate in CMS’ release of the Final Rule, which is expected to be announced by December 1, 2020 for implementation on January 1, 2021. The Proposed Rule is therefore subject to change.

The Proposed Rule includes two new Category I Current Procedural Terminology (“CPT”) code sets related to long term continuous electrocardiogram (“ECG”) monitoring and recording.  Category I CPT codes 93XX0 – 93XX7 will replace Category III temporary CPT codes 0295T – 0298T as the primary codes that iRhythm uses to seek reimbursement for its Zio XT service.  For these and other CPT codes, the Proposed Rule establishes Relative Value Units (“RVUs”) for Work, Practice Expense and Malpractice components that are adjusted by Geographical Practice Cost Indices that account for geographic cost variations and then multiplied by an annually updated Conversion Factor that converts the RVUs to payment rates.

iRhythm notes that the Proposed Rule published on August 3, 2020 does not include all required information, notably the Practice Expense RVU, to calculate the payment rates for the new codes. iRhythm will comment as appropriate following additional information being made available by CMS.

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