To supplement the existing suite of Remote Physiological Monitoring (RPM) codes authorized by Medicare, the Centers for Medicare & Medicaid Services (CMS) has suggested a new category of digital health services called Remote Therapeutic Monitoring/Treatment management. According to the Final rule, which will go into effect on January 1, 2022, RTM is a digital healthcare solution that complements the established RPM system.
What exactly is RTM? In October 2020, the CPT Editorial Panel defined five treatment management service codes under the broad definition “remote therapeutic monitoring” that includes two professional work codes and three practice expense only codes. The CMS’s approval of remote therapeutic monitoring encompasses a variety of non-physiologic and self-reported data, including respiratory system status, musculoskeletal system status, therapy (medication) response, therapy (medication) adherence, and pain monitoring. RTM allows for billing the remote monitoring of a wide range of non-physiologic data, but not precisely therapeutic data.
While some similarities exist between the RPM and RTM codes, RTM codes are not Evaluation and Management (E/M) codes but general medical codes. RPM, on the other hand, is designated as an Evaluation and Management service. CMS has identified some critical differences like the data collected, how the data is collected, and who can charge for RTM services.
- Data collected- The RTM codes allows the gathering of non-physiologic data while monitoring the patient. Ex: Musculoskeletal system status, respiratory system status, therapy adherence, therapy response and pain level. CMS acknowledges “therapeutic” data, not only “physiologic” data, as an essential category of patient information that can be evaluated remotely under these codes
- Clinical use cases– Clinical use cases are currently limited to monitoring respiratory and musculoskeletal systems. The current RTM device supply codes do not address other systems (e.g. neurological, vascular, endocrine, digestive, etc.). CMS stated in the final rule that it received comments suggesting that a general device code be adopted that is system neutral and does not limit RTM reimbursement to monitoring patients’ musculoskeletal and respiratory systems. CMS, on the other hand, did not include a general device code in the final rule
- The kind of data collected by the devices– patient reported data and digital uploaded through the medical devices. While self-reported RTM data via a smartphone app or online platform designated as Software as a Medical Device (SaMD) may qualify for payment, RTM codes still require the device to meet the FDA’s definition of a medical device, according to CMS
- Who can bill for RTM services- Physicians and other qualified healthcare professionals (e.g. Physical therapists, occupational therapists, clinical psychologists, nurses, speech-language pathologists, physician assistants, nurse practitioners, and clinical social workers) are likely to be the main billers under the new RTM codes
- How often can the codes be billed?
- Once each episode of care (When the remote therapeutic monitoring service is enabled, an episode of care begins and concludes with the achievement of specific treatment goals), code 98975 may be billed (every 30-days, the RTM device must monitor at least 16 days of data)
- Once every 30 days, codes 98976 and 98977 may be billed (every 30-days, the RTM device must monitor at least 16 days of data)
- Regardless of the number of therapeutic monitoring modalities conducted in a given calendar month, code 98980 can only be billed once per calendar month.
- For every additional 20 minutes completed within a calendar month, code 98981 may be billed once.
- Those who require non-physiologic respiratory and musculoskeletal monitoring can utilize the new codes. However, all patients who need to stay on track with their medication might benefit from the new codes
According to the AMA Digital Medicine Payment Advisory Group, the RTM’s authorized CMS remote therapeutic monitoring code definitions are:
- CPT Code 98975 — RTM (e.g., respiratory system status, musculoskeletal system status, therapy adherence, therapy response); initial set-up and patient education on use of equipment
- CPT Code 98976 — RTM (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 98977 — RTM (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 98980 — RTM 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 98981 — RTM 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)
Here are some use cases Rx.Health can support but is not limited to
- COPD and Asthma therapeutic monitoring through PROs, Wearables, Apps, and Chatbots
- Musculoskeletal monitoring through wearables, Apps, and Chatbots
- Monitoring medication adherence by collecting automated or self-reported data using chatbots
The growth of RTM services will benefit physician groups and hospital systems with outpatient clinics. Many doctors are now providing their patients therapeutic options that are neither covered nor charged under RPM. RTM will help fill some of the main gaps in care that RPM does not presently cover. It would also widen the pool of healthcare professionals who may bill for these services.
