Here’s what you need to know about remote therapeutic monitoring (RTM) billing codes in 2024, plus other noteworthy updates from CMS
The Centers for Medicare and Medicaid Services (CMS) released the 2024 Physician Fee Schedule final rule, which included clarification on previous stances and new policy announcements in remote patient monitoring (RPM) and remote therapeutic monitoring (RTM) billing codes. In this blog post, we’ll provide an overview of what you need to know about the billing codes, plus other noteworthy updates.
Remote therapeutic monitoring (RTM) vs. remote patient monitoring (RPM)
Remote therapeutic monitoring (RTM) is distinct from remote physiologic monitoring or remote patient monitoring, or any other monitoring involving RPM as an acronym.
Remote therapeutic monitoring involves the use of a medical device (as defined by the Food and Drug Administration) to monitor a patient’s health or response to treatment using non-physiological data. It can be used to keep track of things such as medication adherence, response to therapy, musculoskeletal activity, and respiratory activity. This means that RTM can be used to monitor treatment, for example, specific to pain, functional status, and adherence to exercise therapy. Moreover, RTM allows for self-reported data from the patient.
How is this different from remote patient monitoring (RPM)?
Remote patient monitoring (RPM) describes non-face-to-face monitoring and analysis of physiologic factors to understand a patient’s health status—like blood pressure, blood sugar level, heart rate.1 RPM monitoring cannot include patient reported data. That is, any data collected has to be digitally (i.e., automatically) uploaded to the provider (i.e., data cannot be self-recorded or self-reported by the patient).2 For more details on the latest guidance, review the CMS-released 2022 Medicare Physician Fee Schedule regarding RTM services, plus the newest updates for 2024.
Change to supervision policy for physical and occupational therapists in private practice
Since 2005, CMS has required PTs and OTs in private practices to directly supervise their therapy assistants. The latest final rule announced that CMS is finalizing changes to allow for the general supervision of therapy assistants for RTM services starting January 1, 2024.
- Only one provider can bill in RTM / RPM per 30 days: Only one practitioner can bill RPM codes or RTM billing codes 98976, 98977, 98980, and 98981 in a 30-day period, even if the patient is provided with multiple medical devices from multiple practitioners. Per CMS, “The services associated with all the medical devices can be billed by only one practitioner, only once per patient, per 30-day period and only when at least 16 days of data have been collected.”
- And speaking of the 16-day rule…16-day data collection requirement does not apply to CPT codes 99457, 99458, 98980, and 98981: CMS released clarification that the 16-day data collection rule does not apply to the codes 99457, 99458, 98980, and 98981, which are treatment management codes used for documenting time spent per calendar month.
RPM / RTM billing with other care management services
We’ve established that practitioners cannot bill for both RPM and RTM during the same 30-day period. However, RPM or RTM can be billed concurrently with the following services:
- Chronic care management
- Transition care management
- Behavioral health integration
- Principal care management
- Chronic pain management
Global surgery period and RPM / RTM billing
The 2024 final rule clarified that if the billing practitioner received the global billing payment for a procedure or surgery, that provider cannot also bill for RPM or RTM services provided to the patient during that global billing period. This only applies to the billing practitioners who are receiving the global service payment. Other providers (like physical or occupational therapists) who do not receive this payment can provide and bill for RPM or RTM services provided during the global period.
No “established patient” requirement for RTM
CMS also confirmed that “RPM, not RTM, services require an established patient relationship after the end of the PHE.” CMS noted that RTM services would only be furnished to a patient after an initial patient interaction or evaluation and the establishment of a treatment plan. This will likely be clarified further in future rules.
Rural health clinics (RHCs) and federally qualified health centers (FQHCs) can be reimbursed for RPM / RTM
RHCs and FQHCs can bill for RPM and RTM services using the general care management code (HCPCS code G051), but only for one of the services. The code can be billed multiple times each calendar month. Be sure all requirements are met and that the services billed for are not duplicative of any services that have already been paid for in an episode of care in a given calendar month.
Understanding the RTM codes
There are 5 codes for RTM services. Effective January 1, 2022, health care providers can use these codes to remotely monitor and review data related to signs, symptoms, and functions of a therapeutic response. RTM codes can be separated into two subsections:
- Remote therapeutic monitoring; and
- Remote therapeutic monitoring treatment management services.
Remote therapeutic monitoring codes (98975, 98976, 98977) generally describe initial setup, patient education, and device supply. The two RTM treatment management service codes (98980 and 98981) are meant to be used to report the time the clinician spends managing the RTM treatment.
Each set of codes has specific guidelines that must be considered before providing and billing for these services, so be sure to understand these before billing for RTM.
RTM billing codes 98980 & 98981
And because nothing about billing is ever straightforward, it might help to understand the following about these two codes:
- The time spent should be reported per calendar month.
- Time spent does not include clinical staff time required for data collection.
- At least one interactive communication with the patient or caregiver must take place during the calendar month to bill these codes. This interaction contributes to the total time and does not necessarily represent the cumulative time of the service.
- At least 20 minutes of cumulative time must be completed before reporting 98980 for a calendar month.
- A full 20 minutes must be reached before billing this code. Report 98981 for each additional 20 minutes completed in the calendar month.
- A full 20 minutes must be reached before billing this code.
Defining a medical device
Understanding the definition of a medical device is key if you’re planning to use an RTM code. However, the definition of a medical device is murky at best. Working with your clinical and compliance or legal teams to determine whether the device you intend to use for RTM meets the definition of a medical device will be your best bet in arriving at a clear answer.
CPT Assistant Feb 20224 notes that medical devices, as defined by the Food and Drug Administration (FDA), typically capture data using a signal that measures parameters from “within, attached to or external to the body, or captures an electrochemical or photometric response for a medical purpose.” Commercial insurance providers may have different requirements.
The FDA defines a medical device as “an instrument, apparatus, implement, machine, contrivance…or other similar or related article, including a component part, or accessory which is…intended for use in the diagnosis of disease or other conditions, or in the cure, mitigation, treatment, or prevention of disease [or] injury, in man.”5
The FDA further states that software, depending on its functionality, can also be a medical device.6
Remote therapeutic monitoring (RTM) documentation
Note that rehab therapy documentation requirements for RTM have not been defined by CMS or other payers but it’s worth keeping in mind the following may be required:
- Order for service from physician or other qualified health care professional, such as a physical therapist
- Include RTM in plan of care
- Type of device used – name and description (includes musculoskeletal or respiratory device)
- Specific education and training provided to the patient and/or caregiver
- Data gathered from the device
- Evidence of at least 16 days of monitoring per 30 days
- Date and time of patient and/or caregiver interaction
- Specifics of patient and/or caregiver interaction
- Decisions made that may impact treatment and plan of care
Additional billing considerations
- All RTM services must be provided under a therapy plan of care.
- These codes are considered “sometimes therapy” codes.
- MPPR does not apply to these codes.
- These codes do apply to the annual therapy threshold calculations.
- Codes 98975, 98980, and 98981 are subject to the de minimis standard if provided by a therapist assistant.
- If a patient owns the device used for monitoring, code 98975 should not be billed.
Final words on remote therapeutic monitoring (RTM) billing codes
To sum up, the newest updates in the latest CMS final rule include:
- Change to the supervision policy for physical and occupational therapists in private practice
- Only one provider can bill in RTM / RPM per 30 days
- Clarification on the 16-day data collection requirements
- RPM / RTM can be billed with certain other care management services
- Clarification on the global surgery period and RPM / RTM billing
- Confirmation on the no “established patient” requirement for RTM
- RHCs and FQHCs can bill for RPM and RTM services
Interested in learning more about remote therapeutic monitoring and digital physical therapy?
References:
1 Foley and Lardner, LLP, “2021 Medicare Remote Patient Monitoring FAQs: CMS Issues Final Rule,” 7 December 2020.
2 Foley and Lardner LLP, “2022 Medicare Remote Therapeutic Monitoring FAQs: CMS Final Rule,” 11 November 2021.
3 The American Medical Association, Current Procedural Terminology CPT 2022 Professional Edition, February 2022.
4 VitalWare Software by HealthCatalyst
5 U.S. Food and Drug Administration, “How To Determine If Your Product is a Medical Device,” 16 December 2019.
6 U.S. Food and Drug Administration, “Policy for Device Software Functions and Mobile Medical Applications. Guidance for Industry and Food and Drug Administration Staff,” 27 September 2019.
