The Centers for Medicare and Medicaid Services released their proposed 2022 Medicare Physician Fees Schedule on July 13th. The release was in accordance with five new CPT Remote Therapeutic Monitoring (RTM) codes that deal with non-physiologic patient data, including respiratory system status, musculoskeletal system status, therapy/medication response, therapy/medication adherence, and pain. Although the proposed set of codes is accepted by advocates for virtual care, the proposed MPFS that deals with RTM is likely to bring as many questions as it answers.
Understanding Remote Therapeutic Monitoring Codes
There is a big resemblance between the new proposed RTM codes and the existing Remote Physiologic Monitoring (RPM) codes that were developed a few years ago. Some of the resemblance originates from the two service codes, two device codes, education on how to use the RTM equipment, and the code for set-up. Here is how the Proposed Rule describes the codes:
- CPT Code 989x4: For management and remote therapeutic monitoring treatment services, a qualified health care professional/physician time in a calendar month needing a single interactive communication with a caregiver/patient within the calendar month; the first 20 minutes
- CPT Code 989x5: For management and remote therapeutic monitoring treatment services, a qualified health care professional/physician time in a calendar month needing a single interactive communication with a caregiver/patient within the calendar month; every additional 20 minutes (should be listed separately besides the primary procedure code)
- CPT Code 989x1: Remote therapeutic monitoring including musculoskeletal system status, respiratory system status, therapy response, therapy adherence; the first meetup and educating the patient on how to use equipment
- CPT Code 989x2: Remote therapeutic monitoring including musculoskeletal system status, therapy adherence, respiratory system status, therapy response; supply devices and schedule recordings (e.g. daily), or/and programmed alert communication for monitoring respiratory system, every 30 days
- CPT Code 989x3: Remote therapeutic monitoring including musculoskeletal system status, respiratory system status, therapy response, therapy adherence; supply devices with planned recordings and/or scheduled alert transmission for monitoring musculoskeletal system, every 30 days
The Difference Between Therapeutic Monitoring and Remote Patient Monitoring
Patients, digital health companies, and providers should receive the proposed RTM with open hands as these codes are trying to bridge the gaps present in the current RPM coverage. Here are the differences.
RTM Includes Non-Physiologic Data Monitoring
If the RTM codes are finalized, they will offer coverage for certain data points monitoring. These data points are currently outside of the RPM scope, including medication and pain adherence.
Although the RPM codes relate to physiologic data, in the Proposed Rule, CMS specifies that RTM codes should cover non-physiologic data monitoring. while CMS doesn’t clearly define non-physiologic data, it notes that RTM should monitor health conditions using the provided data such as medication adherence, musculoskeletal system status, medication response, and respiratory system status.
RPM is Offering Payment Parity
CMS has proposed to pay the same rate for RTM services codes 989x4 and 989x5 as the RPM services CPT 99457 and 99458 codes. This is great for qualified health care professionals and therapists.
RTM Covers Self-Reported Data Monitoring
Although RTM will still need to use a medical device as required by FDA, CMS has clarified in the proposed rule that self-reported data may be part of non-physiologic data. the move is a vital difference from the RPM codes, which specify that data should be automatically transmitted through a connected device.
Accepting self-reported data via an app or an online platform that is classified as Software as a Medical Device (SaMD) is important to help monitor metrics such as medication adherence and pain levels, which are not captured and transmitted via the current hardware devices.
CMS seeks to comment on the forms and associated device costs that may be used to do this kind of monitoring to value the device codes appropriately.
RTM is Designed for a Broader Range of Providers
In the proposed MPFS, CMS specifies that stakeholders have agreed that the new coding was designed to allow practitioners who are unable to bill RPM codes to order and bill for services similar to those of RPM. It also points to documents from the RUC (a committee that deals with code valuation) that seem to assume physical therapists and nurses as primary billers for these codes.
The proposed codes come as good news for therapists, psychologists, and other practitioners that cannot currently bill for RPM. However, CMS has noted some uncertainty in the coding structure, and so, it will be paramount for stakeholders to provide comments to ensure flexibility.
Important Questions about Remote Therapeutic Monitoring
The proposed MPFS shows the confusion among the American Medical Association’s CPT Editorial Committee, CMS, and RUC regarding which practitioners can bill for RTM and how they can do it. The confusion needs to be resolved in the final proposed 2022 MPFS if RTM is to be accepted as an integral component of patient care management. Some of the issues include:
Is RTM an “Incident to” Service?
In the proposed MPFS, CMS states that by modeling the new RTM codes on the RPM ones, “incident to” services are included in the three direct practice expense-only codes, and also the two professional work codes.
Consequently, the current RTM codes cannot be billed by some professionals such as physical therapists. This is different from what CMS accepts as an RTM codes primary stated intent, and would seem to suggest that therapists need to bill RTM “incident to” a physician, a physician assistant, or a nurse. Also, unlike the RPM CPT codes 99457 and 99458 codes descriptors, nothing in the description of RTM code shows time spent by a clinical staff, which compromises incident to billing.
Is RTM a Care Management Service?
CMS clearly shows that, unlike RPM, RTM isn’t a care management service. Instead, RPM services are similar to E/M services and physical therapists are practitioners who cannot bill E/M services.
The RTM codes are medicine codes and the treatment management RTM codes (CPT codes 989x5 and 989x4), since they aren’t E/M codes, and they cannot be considered care management services.
Can a QHCP Practitioner Bill for RTM?
CMS keeps mentioning physical therapists as an example of the kind of practitioner who qualifies to bill RTM. Although it can be assumed that speech language pathologists and occupational therapists could also use the RTM codes, it can also be assumed that other QHCPs can also use them to monitor their patients’ vital metrics such as mood. Since CMS also mentions nurses using RTM, which are classified as clinical staff who bill their time to a QHCP or a physician, that answers the question above.
For more information on the proposed CPT codes, or to get started with an RPM program for your clinic today please visit www.accuhealth.tech