With CMS (Centers for Medicare & Medicaid Services) issuing updates to the 2022 Medicare Physician Fee Schedule to include opportunities for remote therapeutic monitoring (RTM), we thought it’s time to discuss what this may mean to our clients.

As a long time provider in the remote patient monitoring space, we are very excited to be able to expand our service offering to new clients – and into new areas of practice.

What is Remote Therapeutic Monitoring?

Over all, the remote therapeutic management codes are designed as direct mirrors of the remote patient monitoring CPT codes, with RTM intended for the management of patients utilizing medical devices collecting non-physiological data.

Despite the planned CMS coverage of remote therapeutic monitoring as outlined in the proposed rule, it’s important to note that RTM is a concept where the specific requirements are still generally undefined.

The CPT descriptions from the American Medical Association are now what we would describe as fairly vague descriptors by CMS in the proposed rule comments. We expect more information on these RTM codes in the coming weeks and will be sharing what we learn as details become clearer, but here’s a quick summary of what CMS seems to be proposing concerning RTM.

How Remote Therapeutic Monitoring and Remote Patient Monitoring Are Different

CMS describes two major differences between RPM and RTM.

First is that many providers that can’t bill for RPM may be able to bill for RTM. In the  rule, Medicare points out that the way the AMA designated the RTM codes as non-evaluation and management (E/M) does not allow Medicare to designate them as general supervision care management codes, hence the reason they are looking for comments about ways to address this disconnect.

Second concerns the nature of the data collected, more specifically therapeutic for RTM versus physiological for RPM. RTM can be used for non-physiological medical devices like those used to support medical adherence (e.g., smart pill reminder systems) and medication symptom/adverse reaction applications. 

Essentially, any information that a medical device — including software that fits the definition of a medical device — can collect that is not physiological can be collected and billed for under RTM.

CMS Remote Therapeutic Monitoring 2022 Codes and Coverage and Coding

Remote Therapeutic Monitoring (RTM) is a family of five codes created by the CPT Editorial Panel in October 2020 and valued by the RUC at its January 2021 meeting — Remote Therapeutic Monitoring/Treatment Management CPT codes 98975, 98976, 98977, 98980 and 98981.

The RTM family includes three PE-only codes and two codes that include professional work — 98980 and 98981:

• CPT code 98980: Remote therapeutic monitoring treatment management services, physician/other qualified healthcare professional time in a calendar month requiring at least one interactive communication with the patient/caregiver during the calendar month; first 20 minutes — base code.
• CPT code 98981: Remote therapeutic monitoring treatment management services, physician/other qualified healthcare professional time in a calendar month requiring at least one interactive communication with the patient/caregiver during the calendar month; each additional add on code 20 minutes (list separately in addition to code for primary procedure).

• CPT code 98975: Remote therapeutic monitoring (e.g., respiratory system status, musculoskeletal system status, therapy adherence, therapy response); initial set-up and patient education on use of equipment.
• CPT code 98976: Remote therapeutic monitoring (e.g., respiratory system status, musculoskeletal system status, therapy adherence, therapy response); device(s) supply with scheduled (e.g., daily) recording(s) and/or programmed alert(s) transmission to monitor respiratory system, each 30 days.
• CPT code 98977: Remote therapeutic monitoring (e.g., respiratory system status, musculoskeletal system status, therapy adherence, therapy response); device(s) supply with scheduled (e.g., daily) recording(s) and/or programmed alert(s) transmission to monitor musculoskeletal system, each 30 days. (Specific to ARIA Physical Therapy device.)

AMA Remote Therapeutic Monitoring Codes: Rules and Requests

What are key coding rules therapists should know? 

• Cumulative time spent for data review and patient/caregiver interaction is totaled for a calendar month (not each 30 days). 
• The base code (98980) and add-on code (98981) are reported together on the claim based on total time following the end of the calendar month. 
• We do not report these codes if activities total less than 20 minutes in a calendar month.
• Codes 98976 and 98977 represent the cost of supplies for specific types of monitoring systems.

What devices can be used for RTM?

Monitoring devices used must be approved by the U.S. Food and Drug Administration, and data collected by the device can be patient self-reported or automatically transmitted directly from the device to the clinician.

One example provided in the proposed rule is as follows:

An asthmatic patient is prescribed a rescue inhaler equipped with an FDA-approved medical device that monitors when the patient uses the inhaler, how many times during the day the patient uses the inhaler, how many puffs/doses the patient uses each time, and the pollen count and environmental factors that exist in the patient’s location at that time. This is non-physiologic data. The data is then used by the treating practitioner to assess the patient’s therapeutic response and adherence to the asthma treatment plan. This can enable the practitioner to better determine how well the patient is responding to the particular medication, what social or environmental factors affect the patient’s respiratory system status, and what changes could be made to improve the patient’s health.

How is RTM impacted by de minimis? 

CMS clarified that the two device codes, CPT codes 98976 and 98977, are not subject to the de minimis standard that establishes the threshold for the statutorily required payment adjustment that applies to therapy services provided in whole or in part by therapy assistants. 

However, the initial set-up and patient education services represented by CPT code 98975 are subject to the de minimis policy. For more information about how the de minimis policy is applied for services provided in full or in part by therapy assistants, see the Therapy pages at section II.H.1. of the final rule.

Other pros here?

To access the full 2022 Medicare Physician Fee Schedule rule, click here.

What else to know?  Support for Chronic Care Management is part of our offering and makes another great tool for use alongside RPM and RTM.

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