By Karen Sartin, MS, CCC-SLP
Product Analyst, Net Health
The CMS 2022 Medicare Physician Fee Schedule Final Rule introduced five new CPT codes for physical therapy, occupational therapy and speech-language pathology, all related to the use of technologies for the collection of non-physiological data outside the clinic setting to inform ongoing treatment planning, also known as remote therapeutic monitoring (RTM).1
RTM requires the use of FDA-defined medical devices that can share manually entered or self-reported data by the patient. By analyzing this data, clinicians make judgments about the patient’s respiratory or musculoskeletal system status, therapy adherence, and therapy response.
Frequent review of this data then allows the therapist to fine-tune therapeutic programming, reinforce target behaviors, and keep the patient engaged throughout the course of care.
Recently, Net Health Therapy polled our users about their use of remote therapeutic monitoring practices, their plans for future use, and what specific devices were being used or considered. We also mined our customer database to determine the frequency with which individual providers and practices are billing these five RTM-related codes.
What we found surprised us: Most were not familiar with RTM, and almost no provider or clinic was routinely incorporating this method of service delivery into their practices.
Let’s explore why it might be worth learning more about how remote therapeutic monitoring can advance your patient and practice goals.
What’s In It for the Patient?
First and foremost, RTM methods provide more regular access to the clinician and their expertise.
These interactions are opportunities to clarify instructions, provide feedback about maladaptive behaviors, and celebrate accomplishments and progress. Regular reinforcement of wellness-related behaviors encourages their generalization and carryover beyond a clinical environment, increasing the likelihood that these behaviors become new self-care routines.
That translates to faster and more enduring functional outcomes, as well as potential cost-savings to the patient, not to mention the health care system!
The patient benefits as incremental adjustments are made to their care plan between sessions, possibly reducing the number of in-person visits to the clinic. This can enhance both convenience and value.
Such benefits become especially important for patients in rural or underserved areas where access to services may be limited. Others who may benefit include those with limited insurance benefits or other social determinants of health that might interfere with active participation in treatment.
The use of everyday technology provides a familiar and efficient means of information exchange with both patients and caregivers.
The therapeutic relationship thus becomes strengthened as trust is established and investment in the patient’s success is demonstrated. The use of remote therapeutic monitoring methods helps hold patients equally accountable to actively engage in their care.
What’s In It for the Practice?
Still not convinced? What if I told you that remote therapeutic monitoring can provide an additional revenue stream and promote better patient engagement resulting in fewer missed visits and self-discharges?
Better clinical outcomes make more satisfied patients, of course, which drives new and repeat referrals. These conditions all lead to improved financial stability and marketability for the practice.
The insight gathered through monitoring activities and patient interactions also enables the clinician to share precise details with the patient’s physician, both strengthening those partnerships and promoting the value of your services.
Keeping the physician engaged and informed is likely to result in a steady stream of new referrals.
Even brief, multiple touchpoints with the patient build rapport and reinforce adherence to the treatment program. Who doesn’t love to see their patients improve?
There is nothing more professionally fulfilling than realizing the efficacy of your joint efforts.
How Can I Get Started with Remote Therapeutic Monitoring in My Practice?
First, familiarize yourself with the documentation and billing requirements outlined by CMS to receive reimbursement for RTM services.
It requires some study to grasp the specifics of these guidelines, as well as careful time and activity tracking to comply with them. CMS never makes things simple!
For patients that are covered by commercial payers, review individual plans and policies to determine coverage, billing requirements and documentation needs.
Next, understand the definition of a medical device according to FDA guidelines2, which you can find here. While CMS does not require that the device be approved by the FDA, it does have to meet this definition.
Once you have an understanding of the criteria, start investigating possible devices based on the populations you serve. There are quite a number of devices and software that are promoting themselves for RTM use.
Ideally, the device you select should help support both data collection and tracking of minutes and days to trigger appropriate billing.
The Bottom Line on RTM
The allowance for RTM reimbursement demonstrates the recognition that related activities (i.e., education, data collection and analysis, and subsequent adjustment of treatment programming) provide value to the patient by promoting improved outcomes in a cost-effective manner.
This is a chance to be paid for work that therapists are likely already performing.
It also provides the opportunity to recapture reimbursement that continues to dwindle in a fee-for-service environment. Don’t leave remote therapeutic monitoring dollars on the table!
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1 Federal Register, “Medicare Program; CY 2022 Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment Policies; Medicare Shared Savings Program Requirements; Provider Enrollment Regulation Updates; and Provider and Supplier Prepayment and Post-Payment Medical Review Requirements,” Nov. 19, 2021
2 U.S. Food & Drug Administration, “How to Determine if Your Product is a Medical Device”