The Centers for Medicare & Medicaid Services (CMS) finalized the 2022 Medicare Physician Fee Schedule. A new category of digital health services, Remote Therapeutic Monitoring (RTM) was added alongside 5 new corresponding CPT codes (98975, 98976, 98977, 98980, 98981).

For the past 4 consecutive years, CMS has expanded coverage for Remote Patient Monitoring (RPM) improving care delivery and patient outcomes while reducing healthcare costs. The new Remote Therapeutic Monitoring (RTM) codes seem to play right into this trend as they broaden use cases and expand the types of practitioners that can order and bill for remote patient monitoring. RTM and RPM appear to mirror each other in ways such a payment parity and code description however there are also some notable differences.

Remote Therapeutic Monitoring

Remote Therapeutic Monitoring is intended for the management of patients utilizing medical devices (including software that fits the definition of a medical device) that collect non-physiological data. It consists of 5 general Medicine CPT codes, billable by providers who are eligible to bill E/M services as well those who are not eligible to bill E/M services such as physiatrists, physical therapists, dieticians, and other qualified healthcare professionals. RTM can be used to monitor medication adherence and response to therapy such as symptoms, side effects, or adverse events. It allows for data to be self-reported or collected by a physical device.

Physiologic vs Non-Physiologic Data

RPM is the collection and monitoring of “physiologic data”, such as blood pressure, weight, or blood sugar. Out of the 4 CPT codes for RPM, one code is designated for the supply of the device(s).

RTM allows “non-physiologic data” to be collected such as therapy (medication) adherence and response to therapy. Out of the 5 CPT codes for RTM, two of them are designated for the supply of the device(s). However, these device codes are currently limited to devices that pertain to the “musculoskeletal system status” and “respiratory system status”.

Self-Reported Data

Both RPM and RTM require the use of a medical device as defined by the FDA (not to be confused with wellness devices). However, unlike RPM, RTM also allows data to be self-reported. This is exciting as it lends an opportunity for software as a medical device to qualify for reimbursement without the need for a traditional physical device or hardware.

Medical Device: Hardware and Software

While medical devices are required for both RPM and RTM, software as a medical device can take the form of a mobile application or a web portal that is designed to monitor and treat disease and meets the FDA requirements of a medical device. There are already many types of software being used to treat patients and that take the place of physical hardware. Removing hardware from the equation creates simplicity and is one less thing a patient needs to deal with.

Who Can Bill: E/M Service Codes vs Medicine Codes

RPM codes are classified as Evaluation and Management (E/M) service codes billable by physicians, advanced practice nurses (APNs), and physician assistants (PAs). This is not the case with RTM. RTM codes are not classified as E/M services and are instead referred to as Medicine or “general medicine” codes which are billable to qualified healthcare practitioners such as physical therapists, occupational therapists, clinical psychologists, registered dieticians, and others.

Who can provide services: General vs Direct Supervision

RPM can be provided under general supervision rather than direct supervision. As an example, a primary care physician can order and bill for RPM while having remote-based clinical staff perform the work under their general supervision.

RTM on the other hand is considered a Medicine code and services must be furnished directly by the billing practitioner or under their direct supervision. Many healthcare stakeholders are questioning this ruling and we anticipate hearing more from CMS soon.

In Conclusion

While RTM brings us another step closer to modernizing virtual care, we believe some additional clarity may be necessary for widespread adoption.

CMS recently stated they have hopes of refining the codes for more efficiency and to address some of the specific concerns raised by stakeholders in the immediate future, which gives us hope we won’t have to wait another year for improvements in the policy.

Below are the 5 RTM codes as finalized for reimbursement

Remote Therapeutic Monitoring/Treatment Management

  • 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 the use of equipment)
  • CPT code 98976 Supply of Device for Monitoring Respiratory 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 respiratory system, every 30 days)
  • 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, every 30 days)
  • 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 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)

If you are considering implementing RPM, have questions, or are just looking for more information, please contact us.  After 10+ years in the space, our team has extensive knowledge and we are here ready to help. We can help clear up any misconception surrounding remote patient monitoring.

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