On November 2, 2021, the Centers for Medicare & Medicaid Services (CMS) approved the 2022 Medicare Physician Fee Schedule Final Rule (MPFS). The MPFS provides information on the new Remote Therapeutic Codes (RTM). This is a major victory for the RPM and RTM Home Health Community. This approval will expand the clinicians able to bill for RTM services.
During our Vision to Virtual keynote, Ann Mond Johnson, CEO of the American Telemedicine Association and Kyle Laverny, VP of Public Policy at the American Telemedicine Association provided a look forward at the game changing bills and policy changes heading into 2022, discussing the new RTM codes.
RTM codes unlike Remote Patient Monitoring (RPM) codes are general Medicine codes that are billable by practitioners who are not eligible to bill E/M services codes unlike those providers who are eligible to bill E/M codes for RPM services. Practitioners such as physical therapists, occupational therapists, dietitians, clinical psychologists, and other QHCPs can bill general medicine codes. These practitioners can order and bill for RTM codes without a physician or nurse practitioner, unlike RPM services.
Unlike RPM services, RTM will look at the following:
- Context of “therapy adherence” and “therapy response”
- RTM will monitor “health conditions, including musculoskeletal system status and respiratory system status”
- RTM will monitor non-physiologic data unlike RPM which monitors physiologic data and patient are able to self-report data unlike RPM which requires Bluetooth submission
- Unlike RPM, which does not limit the provider to health conditions, RTM will focus on “musculoskeletal system status” and “respiratory system status”
Remote Therapeutic Monitoring (RTM) Codes
CPT Code 98980: Monitoring/Treatment Management Services, first 20 minutes
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)
CPT Code 98977: Supply of Device for Monitoring Musculoskeletal System
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)
CPT Code 98976: Supply of Device for Monitoring Respiratory SystemRemote 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 98981: Monitoring/Treatment Management Services, each additional 20 minutes:
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
CPT code 98975: Initial Set Up and Patient Education
(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
The submission of self-reported data will be through an app or web-based platform classified as Software as a Medical Device (SaMD), which monitors metrics like pain levels and medication adherence, which is not captured and transmitted through existing hardware devices.
Payment Parity with RPM
CMS has not published the RTM rates (as of the time of this publication) but stated the rates will parallel the RPM.
The Benefit of the New RTM Codes for HRS Clients
The new RTM codes were created to allow practitioners who cannot bill RPM codes to furnish and bill for services that are like RPM- the goal is to broaden the use cases for RPM by adding these additional RTM codes. For example, Home Health Agencies that provide PT, OT and Speech Therapy to stroke patients on an outpatient basis will be able to provide these services on a remote bases at the patient’s home as a billable service.
As noted in the information provided above the approval and expansion of RTM services will benefit Home Health Agencies, Physician Groups and hospital systems with outpatient clinics. Many HRS clients currently provide their patients with therapeutic services that are not covered and billable under RPM. RTM will assist in closing some of the important gaps in care that are not in the current RPM coverage. It will also expand the scope of clinicians that will be able to bill for these services.
To learn more about the RTM codes, request a conversation with our team.