January 7, 2022 | By Toni Elhoms, CCS, CPC, CPMA, CRC
It’s our favorite time of the year again – coding and regulatory compliance update season! As I’m sure many of my compliance colleagues can relate, this is the time of the year when we get inundated with “Can I pick your brain” requests about the latest and greatest coding/compliance changes and what their impact will bring for revenues. In 2022 – remote therapeutic monitoring is officially the star of the show!
There has been increasing pressure from industry stakeholders to better align real-time patient data collection methods and improving patient outcomes with third-party payer reimbursement. With the advent of remote physiologic monitoring (RPM) codes and reimbursement in 2019, came a mountain of pressure for additional remote monitoring opportunities and the expansion of billable provider types. Since RPM is more restrictive on which provider types can order/ bill for services and has stringent device and data transmission requirements, adoption and program implementation has been limited. Now, all the industry buzz surrounds five new remote therapeutic monitoring codes that are reimbursed by the Centers for Medicare and Medicaid Services (CMS) starting on January 1, 2022.
The new Remote Therapeutic Monitoring (RTM) codes are as follows:
|CPT Code Description||Code Type||
Medicare Non-Facility Reimbursement
|98975||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||Practice Expense||$18.82|
|98976||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||Practice Expense||$54.10|
|98977||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||Practice Expense||$54.10|
|98980||Remote therapeutic monitoring treatment, 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||Professional Work||$48.72|
|98981||Remote therapeutic monitoring treatment, 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||Professional Work||$39.65|
*Disclaimer: CPT Copyright 2022 American Medical Association. All rights reserved. CPT® is a registered trademark of the American Medical Association.
Unlike RPM which focuses on capturing biometric data, RTM utilizes medical devices to collect non-physiological data points, such as: therapy/medication adherence, therapy/medication response, medication symptoms/adverse reactions, pain levels, etc. RTM focuses exclusively on capturing non-physiologic data. To bill for RTM services, the RTM device must meet the definition of a medical device as defined by the Food, Drug, and Cosmetics Act. Currently, RTM services are exclusive to monitoring respiratory and musculoskeletal systems only.
RTM codes have been classified as general medicine services rather than E/M services like RPM, which restricts who can render RTM services. Since RPM is currently classified as an E/M service, it allows providers to leverage clinical staff under their general supervision via incident to billing guidelines to assist them with providing care management services to patients. However, you’ll notice – RTM code descriptions do not include any mention of clinical staff, which means RTM services must be rendered by a physician/eligible qualified healthcare professional. Some examples CMS provided as ideal billing practitioners for RTM services are physiatrists, physical therapists, occupational therapists, and speech-language pathologists.
The RTM codes are structured similarly to RPM with three practice expense codes (CPT Codes 98975, 98976, 97977) designed to capture the initial patient education/equipment setup and ongoing device monitoring. CPT Code 98975 can only be reported once per episode of care, which is defined as starting when the RTM service begins and concludes with the patient’s attainment of targeted treatment goals. Keep in mind, the RTM initial setup and device monitoring codes can only be reported once per 30 days and require at least 16 days of RTM data monitoring.
There are two professional work codes (CPT Codes 98980, 98981) designed to capture RTM monitoring treatment. The RTM monitoring treatment codes are time-based and require at least one interactive communication session with the patient/caregiver in a calendar month. Monitoring treatment services can be reported once per 30 days and require at least 20 minutes of monitoring treatment time to be documented to report CPT Code 98980 and 40 minutes of monitoring treatment time to be documented to report CPT Code 98981. Keep in mind, CPT Code 98981 is an add-on code and must be reported in addition to CPT Code 98980.
Another key difference between RTM and RPM services is the data upload and transmission requirements. RTM services allow for manual entry of self-reported data from the patient, whereas RPM services require the medical device to record and upload biometric data points digitally and automatically.
As compliance professionals, we must exercise diligence when educating our providers about the importance of comprehensive, patient-specific clinical documentation. Some examples of compliance red flags to monitor and address for RTM services are things like, identical time entries for monitoring treatment services across multiple patients, time entries that are mathematically impossible, using non-medically approved devices or wellness wearables for monitoring, lack of medical necessity, cookie-cutter clinical documentation, ineligible ordering/rendering providers, etc.
As the Public Health Emergency (PHE) and COVID-19 Pandemic lingers, third-party payers must continue to evolve and modernize reimbursement opportunities for digital health. As coding/auditing/compliance professionals, we must continue to navigate and master the ever-changing digital health reimbursement and regulatory landscape.