Unlock New Telehealth and Remote Therapeutic Monitoring Opportunities in 2024

2024 Coverage Updates for Telehealth and Remote Therapeutic Monitoring (RTM) in Rehab Therapy

By Rick Gawenda, PT
Founder & President, Gawenda Seminars & Consulting

Prior to COVID-19, the Centers for Medicare and Medicaid Services (CMS) did not reimburse for outpatient therapy services delivered via telehealth by a physical therapist (PT), physical therapist assistant (PTA), occupational therapist (OT), occupational therapy assistant (OTA), or a speech-language pathologist (SLP).

Outpatient physical therapy services delivered via telehealth were considered statutorily noncovered when provided by a PT, PTA, OT, OTA, or an SLP. This meant the Medicare beneficiary was financially responsible for all charges. An advance beneficiary notice of noncoverage (ABN) was not required to be issued to the Medicare beneficiary since outpatient therapy delivered via telehealth was statutorily noncovered.

This all changed due to the COVID pandemic.

Due to COVID-19, CMS has reimbursed for outpatient therapy services delivered via telehealth by a PT, PTA, OT, OTA, or a SLP since March 2020 and, at the time of this article, will continue this coverage and payment through December 31, 2024.

Post-Pandemic Telehealth Reimbursement

If you are a physical therapy private practice, you submit outpatient therapy claims on a 1500 claim form to your Medicare Administrative Contractor (MAC). If you are a facility such as a rehabilitation agency, skilled nursing facility doing Part B, home health agency doing Part B, or a hospital outpatient therapy department, you submit outpatient therapy claims on a UB-04 claim form to your MAC.

On the 1500-claim form, there is a field that requires a “Place of Service” (POS) code. This POS code tells your MAC where the therapy visit occurred.

For calendar year 2024, therapists in private practice who provide outpatient therapy services via telehealth are to use the POS code of where the visit would have occurred if it occurred in-person. For example, if the Medicare beneficiary had come to your clinic, the POS code would be 11. If you had seen the Medicare beneficiary in their home as an outpatient, the POS code would be 12.

For both private practices and facilities (non-private practices), all the documentation, billing, and modifiers are the same for outpatient therapy delivered via telehealth as they are for in-person visits. The one addition is you must append modifier 95, in addition to all other required modifiers, to each CPT® code on the claim form. Modifier 95 indicates this visit was provided via telehealth.

To view a list of the CPT® codes that CMS reimburses when delivered via telehealth, see the “List of Telehealth Services” page on CMS.gov.

Regarding Medicare Advantage, Medicaid, and Medicaid Advantage, and commercial insurance carriers, you will have to check with each plan individually to determine if they reimburse for outpatient therapy services delivered via telehealth.

Tips and Updates for Remote Therapeutic Monitoring (RTM)

Effective January 1, 2022, there were 5 new CPT® codes to describe RTM. Those 5 codes are as follows per the American Medical Association (AMA) CPT® 2024, Professional Edition:

• 98975 – Remote therapeutic monitoring (e.g., therapy adherence, therapy response); initial set-up and patient education on use of equipment
• 98976 – Remote therapeutic monitoring (e.g., 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., 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 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 – 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; each additional 20 minutes (List separately in addition to code for primary procedure)

In 2023, the AMA released an additional CPT® code for RTM which is as follows:

• 98978 – Remote therapeutic monitoring (e.g., therapy adherence, therapy response); device(s) supply with scheduled (e.g., daily) recording(s) and/or programmed alert(s) transmission to monitor cognitive behavioral therapy, each 30 days

CSM Billing Guidelines for RTM Codes

CMS has given a status indicator of “A” to CPT® codes 98975, 98976, 98977, 98980, and 98981, which indicates an active code. This means these codes are separately payable under the Medicare Physician Fee Schedule. There will be relative value units (RVUs) and payment amounts for codes with this active status.

CMS has given code 98978 a status indicator of “C”. Status indicator “C” means Carriers/MACs-priced code. Carriers/MACS will establish RVUs and payment amounts for these services, generally on an individual case-by-case basis following a review of documentation.

CPT® code 98975 is billed only once per episode of care and only after 16 days of monitoring have occurred. Per the American Medical Association, CPT® Changes 2022: An Insider’s View, an episode of care is defined as “beginning when the remote therapeutic monitoring service is initiated and ends with attainment of targeted treatment goals.”

CPT® codes 98976, 98977, and 98978 are billed every 30 days from when the episode begins and only if 16 or more days of monitoring occur during every 30-day period.

In order to bill one unit of 98980, you must provide the entire 20 minutes of remote therapeutic monitoring treatment management services. To bill one unit of 98980 and one unit of 98981 in the same calendar month, you must provide the entire 40 minutes of remote therapeutic monitoring treatment management services.

Nuances to Medicare RTM Billing

CMS has designated all six of the RTM CPT® codes as “sometimes therapy” CPT® codes. This means when the RTM codes are billed under an outpatient therapy plan of care, the allowed amount for each CPT® code will count toward the annual therapy dollar threshold, but the multiple procedure payment reduction policy will not apply. In addition, since billed under an outpatient therapy plan of care, you must also attach the discipline-specific modifier (GN, GO, or GP) to each CPT® code.

If CPT® codes 98975, 98980, and/or 98981 are provided in whole or in part by a physical therapist assistant or an occupational therapy assistant, you will need to append the CQ or CO modifier respectively to those CPT® codes on the claim form. The CQ or CO modifier does not apply to CPT® codes 98976, 98977, or 98978.

In order to bill CPT® codes 98975 through 98978, the device used must meet the definition of a medical device per the Food and Drug Administration (FDA), but need not be an approved medical device.

RTM® is not considered a therapy visit and should not replace medically necessary in-person therapy visits but should be used as a hybrid to supplement a patient’s therapy needs in between therapy visits. If done correctly, a therapy practice should see improved patient compliance with attending their in-person therapy sessions, improved patient outcomes, improved percentage of patients completing their plan of care, and of course, increased revenue to the practice.

Lastly, this blog does not serve as consulting advice. If considering implementing RTM, I recommend you contact a consultant with an understanding of RTM implementation as well as a thorough understanding of the rules and regulations related to documentation and billing.

About the Author

Rick Gawenda, PT, is a licensed physical therapist with over 30 years of experience and currently serves as the founder and President of Gawenda Seminars & Consulting, Inc. He graduated with a Bachelor of Science degree in Physical Therapy from Wayne State University in Detroit, Michigan, in 1991. Gawenda previously worked as the Director of Physical Medicine and Rehabilitation at Detroit Receiving Hospital where he was responsible for physical therapy, occupational therapy, and speech-language pathology services, both in the inpatient and outpatient setting.

He has provided valuable education and consulting to hospitals, private practices, skilled nursing facilities, and rehabilitation agencies in the areas of CPT coding, ICD-10 coding, billing, documentation compliance, revenue enhancement, practice management, and denial management as they relate to outpatient therapy services. Gawenda has presented nationally since 2004 and currently presents approximately 100 dates per year around the United States.