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CMS Proposes New Remote Therapeutic Monitoring Codes

By Gerald Buggs, MSJ

In the 2022 Medicare Physician Fee Schedule CMS proposed five new CPT codes for Remote Therapeutic Monitoring (RTM). These 5 new codes broaden the use cases for Remote Patient Monitoring (RPM) beyond the existing RPM codes. The RTM codes include monitoring for non-physiologic patient data such as musculoskeletal system status, respiratory system status, therapy (medication) adherence, therapy (medication) response, pain, and other conditions.

If approved, the RTM codes will cover and fill in some of the gaps that are not covered in RPM currently.

Included below is information from CMS on what the RTM codes cover and the difference between RTM and RPM services. 

 

RTM

RPM

Reporting of non-physiologic data. (Including musculoskeletal, respiratory, therapy medication adherence, therapy medication response)

YES

NO

*Self-reported data collected by a device defined by the FDA

YES

NO

(RPM requires data submission to be automatically transmitted by a connected device)

Billing providers include, Nurses, PT, OT, Speech Pathologists & other practitioners

YES

NO

*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. This is an area of discussion that CMS is seeking comments on during the review period along with associated cost of devices.

In the 2022 Proposed MPFS CMS states and references “the committee responsible for valuation of codes…seem to anticipate nurses and physical therapists as primary billers." This is good news for physical therapists, occupational therapists, speech language pathologists, clinical psychologists and other practitioners that are not currently eligible to bill for RPM.

Payment parity with RPM:

  • CMS is proposing to pay RTM service codes 989X4 and 989X5 at the same rate as the parallel RPM service CPT codes 99457 and 99458.

The new RTM codes in the Proposed Rule

  • CPT code 989X4 - 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 989X5 - 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 989X1 - 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

  • CPT code 989X2 - 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

  • CPT code 989X3 - 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

There are still outstanding questions about RTM services including which types of therapists or Qualified Health Care Professionals (QHCP) will be allowed to bill for RTM and how it should be done. 

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 similar to 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 HRS 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.

We strongly encourage you to submit your commentary at http://www.regulations.gov/

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