Remote Therapeutic Monitoring, all there is to know.

CMS has continued the trend of expanded Medicare reimbursements for remote monitoring by releasing the 2022 Physician Fee Schedules final rule on its new RTM codes.

The new RTM Codes broaden the use cases for remote patient monitoring beyond the existing RPM codes and represent one of several recent advancements to modernize reimbursement of digital health.

The RTM Frequent Asked Questions below are based upon CMS’ policies in its 2022 Final Rule.

Remote Therapeutic Monitoring

1. What are Remote Therapeutic Monitoring (RTM) codes?

RTM is a set of five codes created by an editorial panel in October 2020 and valued at $1,000 by the RVS Update committee (RUC) at their January 2021 meeting. The new RTM code is:

CPT# 98975

Description: Remote therapeutic monitoring (i.e., respiratory system status, muscu­loskeletal system status, adherence to therapy, therapy response)

CPT# 98976

Descriptor: Therapeutic monitoring via remote devices; device(s) supply for scheduled recording(s) and / or programmed alerts transmission to monitor respiratory system; each 30 days

CPT# 98977

Descriptor: Therapeutic monitoring via remote devices; device(s) supply scheduled recordings and/or alerts for monitoring musculoskeletal systems, each 30 days

CPT# 98980

Descriptor: A remote therapeutic monitoring treatment requires at least one interactive communication between the patient/caregivers and their healthcare provider during the calendar month.

CPT#98981

Descriptor: A remote therapeutic monitoring treatment requires at least one interactive communication between the patient/caregivers and their healthcare provider during the calendar month. Each additional 20 minutes of interaction costs $20.

There are some similarities between the structure and nature of RTMs and RPMs. However, there are notable differences between them.

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2. Can RTM be used for non-physiological data?

Yes, RTM was designed for the management of patients using medical devices that collect data about non-physiological aspects of patient care. Data around indicators such as therapy/medication adherence and therapy/medication response can be collected and billed using the new RTM codes under these codes, CMS recognizes « therapeutic » data—not just « physiologic » data—as an important type of patient information that can be assessed remotely. This differs from RPM codes, which can be used only in conjunction with tracking physiologically based data (e.g. heart rate, blood pressure, and blood sugar levels).

Compared to RPM, RTM codes offer the potential for broader use cases and applications across the healthcare system. The list of RTMs health conditions identified in the codes is meant to be illustratory and not exhaustive (hence the use of “eg.”). In the proposed PFS rule, CMS added the word “medication”—“adherence, and response”—but that word is not found in the CPT code descriptions. It is unclear what AMA or RUC materials CMS used when inserting the word “medications” into its PFS commentary.

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

An asthmatic person has prescribed a rescue inhalation device equipped with an FDA-approved medical device that monitors when he/she uses the inhaler, the number of times per day the person uses the inhaler and the pollen count in the area where the person lives. This is non-pharmacological data. The data is used by the treating physician to assess the patient‘s therapeutic response and adherence. This enables the physician to better determine how well he/she is responding to the particular drug, what social or environmental conditions affect the patient respiratory system status, and how changes could be made to help the patient’s condition.

3. Is RTM limited to respiratory and musculoskeletal conditions?

Yes, the clinical uses eligible for RTM device supply reimbursement are limited. The two device supply codes (98975, 98976) are similar to the device supply code (99453), but not identical. The CPT code 99453 does not restrict the clinical systems being monitored, although it requires the data to be physiological. In contrast, the two RTM device code descriptors themselves indicate much more limited clinical uses. Specifically, 98975 is only for transmissions to measure the respiratory system, whereas 99876 is only for transmissions measuring musculoskeletal systems. The current RTM device supply codes do not target any other systems (e. g., neurological, vascular, digestive, endocrine, etc.). In the proposed rule, CMS acknowledged it had received comments that a general RTM device code should be created to allow for monitoring of any patient condition. But CMS did not create such a general device code.

Stakeholders are hopeful CMS will include an expanded set of conditions in the future, including those related to cognitive behavioral therapy (CBT). In early November 2021, the American Medical Association (AMA) announced revisions to the Current Procedural Terminology (CPT) codes for Rehabilitation Technical Manual (RTM) to clarify the coding of CBT monitoring services.

4. How are RTF codes classified?

The RTM codes consist of two parts: the first part is the diagnosis code, and the second part is the procedure code. The diagnosis code indicates what was done during the visit, and the procedure code indicates how the patient was treated. For example, if a patient had a broken arm, the diagnosis code

5. What practitioners should order and deliver RTM?

Physicians and eligible qualified healthcare professionals are permitted to bill RTT as general medicine services. A physician or other qualified healthcare professional means an individual who is qualified by education, training, licensure, regulation, and facility privileging (if applicable) and who performs a medical service within his/her area of expertise and independently reports that medical service. Accordingly, RTT codes could be available for PTs, OTs, SLPs, PAs, NP, and CSWs. In the final rule published in the Federal Register, CMS stated the primary payers of RTT codes are projected to be PTs, OTs, and SLPs. The new RTT codes, classified as general medical codes, should open up opportunities for therapists, psychologists, and other eligible practitioners who cannot presently bill for RPM (as RTM is an E/M code).

6. Is incident billing under general supervision allowed?

No. Because the 2 RTM treatment management codes CPT codes 98980 and 98881 are not E/M codes, they cannot be designated care management services. This means a physician could not order an RTM service while having remote-based NPPs perform the work under general supervision.

RPM allows billing practitioners who bill under general supervision to leverage clinical staff via incidents to billing. However, as a general medical code, RTM does allow billing practitioners under general supervision to perform RMT services for the billing provider, and the final rule states that where a practitioner‘s Medicare benefit does not cover services furnished incident to their practice, the RMT services must be performed directly by the billing practitioner, or in the case of a physical therapist (PT) or occupational therapist (OT), by a therapy assistant under their direct supervision. Also, unlike RPM CPT code descriptions, nothing in the descriptions of the RTM codes mentions the time spent by clinical staff, although the final rule does state that « the time spent by the billing practitioner performing the service may be included in the total time billed. »

7. How many hours of service are required for RTO?

CPT code 99890 requires a minimum of 20 hours per month, dedicated to remote therapy management of the patient. At least one hour of this time must be spent interacting with the patient/caretaker during the month (via phone or video).

CPT code 98985 has the same requirements as code 98980, except it’s used for additional 20 minutes each month, as an add-on code.

8. How often do you charge your customers?

Code 98975 can be billed once per episode. An episode of care starts when the remote therapeutic monitoring system initiates and ends with the attainment of target treatment goals.

Codes 98976 or 98977 may be charged once every 30 days.

Code 98980 can be billed once per calendar year regardless of the number of diagnostic tests performed in a given calendar year. Code 98981 can be billed once per year for each additional 20 minutes spent performing diagnostic testing.

9. Are RTMs subject to the de minimus standard?

The device codes are NOT subject to it, but THE EDUCATION CODE IS. In the final rule, CMS designated the five RTT codes as “sometimes treatment codes.” As “sometimes treatment codes,” the RTT services can be billed outside of a treatment plan of care when provided through a physician and certain NPPS, but only when appropriate (i.e., when the service is provided by an NPPS).

CMS stated the two CPT codes, 98976 and 98877, are not subject to the de minimis standard. However, the initial setup and patient education services (98875) are subject to a de minimis policy that determines the number of payment adjustments for therapy assistant services. CMS provides an example in the final rule illustrating how the de minimis policy would apply for the RTM treatment manager services that describe the interactive communication between the therapist and/ or therapy assistant and the patient/caregiver.

10. Does RTTM require the use of a medical device, or can it just be a wellness wearable?

You need a medical device to use RTM.

11. How many hours of data must the device record?

CPT codes 98895, 98896, and 98897 require the RTM device to be used for at least 16 days per 30-day period, totaling 96 days of monitoring.

12. Can RTT data be self-reported?

Yes. In the Final Rule, CMS stated that self-reported/entered data may also be used as non-physiologic information for purposes of coding.

86 FR 64995 (Nov 19, 2021), 65116 (Nov 19th, 2021) (‘Reportedly, RTMs can be patient-reported, along with digitally uploaded while RPM requires data to be physiological and be digitally uploaded. ’). While RTM codes continue to require the device used to satisfy the FDA’s requirement of a medical device, reported RTM data via a mobile phone app or online platform is classified under the FDA’s new classification system as a ‘medical device’.

(SaMD) can qualify for reimbursement, according to CMS. This differs from RMP codes, which require the digital recording and uploading of patient physiologic data (data cannot be patient self-recording, self-reported, or entered manually into the device), and thus are not eligible for reimbursement.

Conclusion

Entrepreneurs and providers who offer remote monitoring technologies and services to patients should take steps now to learn about these new billing opportunities under the Medicare program. Remote monitoring will continue to grow as an area of significant opportunity over the next few years. Hospitals and healthcare providers using RPM, RTMs, and other non-face-to-face technologies should take a serious look into these new codes, and stay abreast of developments in this area that can drive recurring revenue.

To learn more about telemedicine, telesurgery, virtual care, remote monitoring, digital health, digital health, and related topics, including the team, industry publications, and representative experience visit Foley’s Telehealth & Digital Health Industry Team page.

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