Starting January 1, 2022, there are five new Remote Therapeutic Monitoring (RTM) codes.
Remote patient monitoring (RPM) allows healthcare providers to keep tabs on patients remotely using connected health devices and technologies. RPM utilization soared during the pandemic as physicians could monitor patients without coming into physical contact with them, preventing the spread of coronavirus. Data provided by RPM devices is collected and used to guide treatment for the monitored conditions. Medical billing outsourcing to certified billing and coding professionals helps physicians ensure accurate coding and claim submission for RPM.
The 2022 Physician Fee Schedule final rule on new Remote Therapeutic Monitoring (RTM) codes introduced by Centers for Medicare & Medicaid Services (CMS) is officially titled “Remote Therapeutic Monitoring/Treatment Management.” CMS had made some significant changes concerning RPM and the provision of other remote services in the 2021 Medicare physician fee schedule final rule. The 2022 RTM codes expand the opportunities for Medicare reimbursement of remote monitoring beyond the existing Remote Patient Monitoring (RPM) codes. While the structure and nature of RTM services and codes resemble those of RPM services there are notable differences. Practices providing remote monitoring services should take the time to understand these changes and ensure that they comply with the new rules.
Four New RTM Codes
The RTM code set includes three practice expense (PE)-only codes and two codes that include professional work. The new RTM codes are:
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
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
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
98980: Remote therapeutic monitoring treatment, physician/other qualified health care professional time in a calendar month requiring at least one interactive communication with the patient/caregiver during the calendar month; first 20 minutes
98981: Remote therapeutic monitoring treatment, physician/other qualified health care professional time in a calendar month requiring at least one interactive communication with the patient/caregiver during the calendar month; each additional 20 minutes
Features of the New RTM Codes and Services
- Bill both physiologic and therapeutic data: In addition to “physiologic” data, CMS recognizes that “therapeutic” data is an important category of patient information that can be assessed remotely. The new RTM codes are designed to collect and bill non-physiological or therapeutic data such as such as therapy/medication adherence, therapy/medication response, and pain level. On the other hand, the RPM codes can be used only in combination with tracking physiologic data (e.g., heart rate, blood pressure, and blood sugar levels).
- Limited to respiratory and musculoskeletal conditions: The clinical use cases eligible for device supply reimbursement under the two RTM device supply codes (98976, 98977) are limited. While code 98976 is only for transmissions to monitor respiratory system, code 98977 is only for transmissions to monitor musculoskeletal system.
- Classified as general medicine codes: Unlike RPM which is classified as an Evaluation and Management (E/M) service, the RTM codes are classified as general medicine codes and not E/M codes. RTM codes can be billed as general medicine services by physicians and eligible qualified healthcare professionals.
- Cannot be labelled care management services: CPT codes 98980 and 98981 are not E/M codes and therefore cannot be designated as care management services. With RPM, billing practitioners can allow clinical staff under general supervision to perform RTM services, CMS states that RTM must be furnished directly by the billing practitioner or, in the case of a PT or OT, by a therapy assistant under the PT’s or OT’s supervision.
- Time requirements and billing frequency: The time requirements for codes 98980 and 98981 are the same, except code 98981 is an add-on code:
98980 Remote therapeutic monitoring treatment management services, physician/other qualified health care professional time in a calendar month requiring at least one interactive communication with the patient/caregiver during the calendar month; first 20 minutes
98981 each additional 20 minutes (listed separately in addition to code for primary procedure)
- 98975 may be billed once per episode of care
- 98976 and 98977 may be billed once per 30 days
- 98980 may be billed once per calendar month regardless of the number of therapeutic monitoring modalities performed in a given calendar month
- 98981 may be billed once per calendar month for each additional 20 minutes completed within such month
- De minimis standard: The de minimis standard refers to services provided “in whole or in part” by a physical or occupational therapy assistant. RTM device CPT codes 98976 and 98977 are not subject to the de minimis standard, but the initial set up and education services designated by CPT code 98975 are subject to the de minimis policy.
- Requires use of a medical device: RTM requires the use of a medical device as defined under the federal Food, Drug, and Cosmetics Act (not just a wellness device). For billing CPT codes 98975, 98976, and 98977, the RTM device has to monitor at least 16 days of data per each 30-day period, in total.
Finally, CMS has stated that RTM data can be self-reported by the patient, and that self-reported RTM data via a smartphone app or online platform classified as Software as a Medical Device (SaMD) may qualify for reimbursement. This is different from RPM, where the data has to be automatically uploaded by the device itself, and not be self-recorded, self-reported, or entered manually into the device by the patient.
With CMS continuing to expand reimbursement for remote monitoring, outsourced medical billing services are a practical strategy for providers offering virtual care and remote monitoring to stay updated on the latest codes and billing rules.