remote patient monitoring code

2022 Medicare Remote Therapeutic Monitoring FAQs: CMS Final Rule | Blogs | Health Care Law Today | Foley & Lardner LLP

CMS has just announced the release of the 2022 Physician Fee Schedules final rule. Five new RTM code categories were added. They're scheduled to become effective beginning January 1, 2022.

These new RTM code updates expand the uses for Medicare reimbursements of remote patient monitoring beyond the current RPM coding system. They represent one of the latest advances in modernizing healthcare reimbursement for digital health.

The FAQs below are based on CMS’ policies in the final rule published in June of 2020.

1. What are the Remote Therapeutic Monitoring codes?

The RTM family consists of three PE-only code families and one code family that contains both PE and professional work. The new code families are:

CPT# 98975

Descriptor: Therapeutic remote health care; initial setup and patient education on use

CPT# 98976

A descriptor for remote therapeutic monitoring is "remote therapeutic monitoring" (e.g., respiratory monitoring). It includes devices that provide scheduled recordings and/or alerts to be transmitted to a central location at least once every 30 days.

CPT# 98977

Device(s): Remote Therapeutic Monitoring (RTM), e.g., Respiratory Status, Musculoskeletal Status, Adherence, and Responsiveness; Scheduled Recording(s) and/Or Alert Transmission(s) for Monitoring Musculoskeletal Systems, Each Thirty (30) Day Period

CPT# 98980

Description: A remote therapeutic management program for patients who require medical supervision by a physician or other qualified health care professional (e.g., nurse practitioner) in a specific timeframe.

CPT#98981

Description: Remote therapeutic monitoring treatments require at least one interaction between the caregiver and the person receiving the service, which may include an online conversation via telephone, video conference, text message, email, etc., within a given month.

There are some similarities between the structure and nature of RTMLT codes and the codes for RPMs. However, there are significant distinctions between them.

Understanding the terminology for RPM Codes:

Health technologies, current procedural terminology.

Remote patient monitoring, patients, rpm, cpt, reimbursement, medicare, cms, telehealth, payment, healthcare, asha, physician, audiologists, cpt code, hrs, therapeutic, fee, rtm, covid-19, monitoring.

Digital health, perfusion index, value-based healthcare, remote physiologic monitoring, emphysema, quality of care, chf, health insurance portability and accountability act, revenue cycle management, lpns, readmission, lung, copd, telemedicine, speech-language pathology, nurses, rns, monitoring, adherences, patient monitoring, telehealth services.

Monitoring, patient, codes, cpt, care, code, rpm, services, patients, health, data. Reimbursement, cms, devices, telehealth, month, medicare.

Management, device, minutes, rtm, program, providers, billing, time, days, system, blood, healthcare, communication, payment, therapy, provider, hrs, bill, service, pressure, treatment, status, calendar.

Remote patient monitoring, cpt code, patient monitoring, cpt codes, calendar month, therapeutic monitoring, rtm codes, remote monitoring, interactive communication.

Physician fee schedule, patient education, medicaid services, rpm services, emr experience, patient data, therapy adherence, remote patient, 30-day period, management services, rpm devices.

Therapy response, rpm program, professional time, public health emergency, blood pressure, chronic care management, patient monitoring program, respiratory system status, musculoskeletal system status.

Does RTM actually work for non-biological data?

Yes. RTM was designed for the management of patient care through remote monitoring of patients who use medical devices that capture non-physiological patient conditions. These include therapy/medications adherence, therapy/medications responses, and pain level. With these new RTM code sets, CMS recognizes "therapeutic" patient condition as an important category of patient health status that can be assessed remotely and billed under the new code set. This differs from RPM code sets, which can only be applied to patient care where physiological patient conditions are monitored.

Compared to RPM, RTM offers the promise of a broader use case and application in patient healthcare. The listing of RTM health condition codes is intended to be illustrative and is not exhaustive. In the proposed PFS rules, CMS added the word "medications" - "adherence", and "response". But that word is not found in the CPT code descriptor. It is unclear whether AMA or RUC material was used when CMS inserted the word "medications".

Here's an example of how RTM could potentially be used:

An asthmatic person is given a rescue inhaler equipped to monitor his/her usage of the inhaler, how often he/she takes the inhaler, how much medicine is taken per dose, and the amount of pollen and environmental conditions present in the area where the inhaler was being used. This information is collected by the monitoring equipment and sent to a database. This allows the doctor to see if the person is taking the medicine properly, whether they are complying with the treatment plan, and how effective the treatment is working. In addition, the doctor may be able to make adjustments to the treatment plan based on the results of the monitoring.

RTM is not limited to respiratory and musc­loskeletal conditions.

Yes, the clinical usage scenarios eligible for RTP are limited. The two RTP device supplies (98976, 98997) are similar to the RPM devices supplies (99454, 99954), but not exactly alike. CPT codes 99454 and 99954 do not limit the clinical or biological systems that can be measured, although the measurement must be physiological. In comparison, the two RTP device supplies themselves indicate much more restricted clinical usage. Specifically, 98996 is only for transmission to measure the cardiovascular system, whereas 98976 is only used for measuring the respiratory system. The current RTP device supplies do not address other systems (e. g., nervous, vascular, endocrine). In the final rule, Medicare recognized it got comments that general RTP device supplies should be developed that would be system agnostically and not limit RTP reimbursements to measuring patient's musculoskeletal or respiratory systems. However, Medicare did not create such a general RTP device code in the final rule.

Stakeholders are hopeful CMS will expand its list of conditions in the near term. For instance, in early November 2021, the American Medical Association (AMA) announced revisions to the Current Procedural Terminology (CPT) codes for cognitive behavioral therapy (CBT) to clarify their use for CBT treatment management.

What are RTM codes?

The RTM codes fall under the general category of medical services, but they're not Evaluation and Management (EM) codes. In comparison, the RPM codes are considered evaluation and management services.

Practitioners can use RTM to create an online store for their practice.

Physicians and eligible qualified healthcare professionals may charge RTM as general medical procedures. A medical practitioner or other qualified healthcare professional may be described in the CPT® 2015 Procedure Coding Manual as “a person who is qualified by education and training, licensure/registration (when applicable), and facility privileges (when applicable) who provides a professional health care procedure within his/her area of competence and independently submits that professional health care procedure.” Accordingly, the proposed RTM billing category would allow PTs, OTs, SLPs, PAs, NP/PAs, and SWs to submit claims for these procedures. In the final rules, CMS indicated the primary payers of RTM coding would likely be physiatrists, NPS/PNPs, and PTs. The new RTM categories, categorized as general medical procedures, would provide opportunities for other eligible providers who cannot currently claim RPM (as RPM is an E/M procedure).

Incident to Billings Under General Supervision (RTM) is allowed.

You're wrong. CPT code 98980 and CPT code 98981 are not E/M code numbers. Therefore, physicians cannot order and bill for RTMs while having non-physicians remotely provide the service.

RPM (Radiology Procedure Modifier) is used to bill for radiology procedures performed by radiologists, technologists, medical assistants, and/or technicians under the direct control of the physician performing the procedure. These services may be billed either through an existing claim or by submitting a new claim. For example, if a physician performs a CT scan of the head, he or she can submit a claim for the service rendered by the technician who operated the machine. Alternatively, the physician can submit a separate claim for the radiological interpretation of the images taken during the procedure. The RPM modifier is assigned based on the type of procedure being performed. For example, if the physician performs a biopsy on a patient, the physician would assign the appropriate modifier. Similarly, if the physician performs an MRI, the physician assigns the appropriate modifier.

7. What is the number of hours required for RTM?

A CPT code for telehealth services must be billed separately from any other codes used to bill for the service. It is not allowed to combine these two types of services into one claim.

For example, if you're billing for 30 minutes but actually worked for 40 minutes, then you would use the additional time (20 minutes) as an extra charge.

You can bill each code up to eight times per month.

If you use code 98975 for each visit, you’ll get one bill per visit. However, if you use the code for every visit, you’re billed for an entire year.

Codes 98976 (90012) and 98977 (90013) may be billed once per month.

If you perform one or more therapeutic monitoring modality codes during any given 30 day period, you may bill up to three times for code 98980 (once per 30 days) and up to four times for code 98981 (once per 30 days).

Is there an exemption for RTM codes?

The device code is not subject to it, however, the education code is. The final regulation states that the five RTM service types are “sometimes treatment services.” As such, they may be paid for outside of a medical necessity when provided by a doctor and certain NPPs, but only when appropriate (i.e., if the service is medically necessary).

CMS states that the two RTM device coding rules, CPT 98976 and 98877, are not subject to the de minimus standard but that the initial setup and education service (CPT 98975) is subject to the de minimus standard. CMS provides an example of how the de minimus standard would be applied to the RTM treatment management service that describes the interactive communication between the therapist and/ or the therapist and the caregiver.

9. Is there any evidence that RTM requires the use of a medical device, or can it be used for wellness purposes?

You must obtain FDA approval for any product that uses radio frequency energy.

You need at least eleven (11) days of data for each day of testing.

To qualify for coverage under these three CPT codes, the RTM must be used continuously for at least 16 consecutive days during each 30-consecutive-days monitoring interval.

Does the patient need to report their own symptoms?

Yes. In the Final Regulation, CMS stated that "non-physiologic" (e.g., reported/entered) patient-specific information could be used for purposes of reporting RTM codes.

As long as the device used to collect the respiratory rate measurement meets the FDA's definition of an electronic medical device, then any type of respiratory rate measurement collected using a smartphone app or online portal would qualify as "patient-recorded" under the new rules.

If your SaMD qualifies for Medicare coverage under the new rules, you can get reimbursed for its purchase. However, if your SaMD doesn't meet the requirements for Medicare coverage, you won't be able to get reimbursed for its cost.

Conclusion

As an entrepreneur or provider offering remote patient monitori­ng technology and services, you need to be aware of the upcoming changes to Medicare billing for these types of services. These new coding opportunities offer tremendous upside potential, and hospitals and healthcare organizations using remote patient monitors should consider them carefully.

To learn more about telemedicine, telesurgery, virtual care, remote monitoring, digital medicine, and other healthcare technologies, including the team, resources, and representative experience, please click here.