Pioneers in Remote Therapeutic Monitoring (RTM) Software for Physical Therapists

By Andrew Gorecki, DPT, PT, FAFS

Remote Therapeutic monitoring is a relatively new area in the physical therapy industry, and some providers have adopted RTM early, while others are waiting to see how it all plays out. For those who have adopted this new service and CPT codes early like me, there have been many challenges on the billing side, and in this article, we will explore the basic understanding that is required to be successful in providing the service of remote therapeutic monitoring and also getting paid for the service that you provide.

CPT Code Rules

Let’s start with the basic understanding of each new CPT code and the rules associated with these new codes.

Per the American Medical Association (AMA) CPT 2023, Professional Edition, the new CPT codes and their descriptors are as follows:

• CPT 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. Can be billed 30 days after the patient is added to the software system.
• CPT 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
• CPT 98980 – 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 98981 – 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)

As you can see, each code has a time requirement to consider as it relates to submitting these codes for reimbursement. Some are every 30 days and others are per calendar month. The easiest way I’ve encountered submitting these codes is after the month has ended, submitting these codes as a group per patient. Your software program that you are using for an HEP and RTM should have the ability to automatically track the rules above and produce the CPT codes for you when appropriate, providing you with a billing report to then submit these codes for reimbursement.

Read More: Counties Included in 2020 Localities, Listed Alphabetically by State and Locality Name within State – cms.gov

How to Locate Reimbursement Amounts

Finding the reimbursement amounts can be challenging for commercial payers. However, Medicare is very transparent, and they post their reimbursement rates on their website. The first step is to identify your MAC Locale by using this website: [Link to CMS website]. This will allow you to find the locality key for your county or region. Then, using that locality key, you can then use this website: [Link to Medicare Physician Fee Schedule search] By entering the CPT codes from above with your regional locality key, you will be able to find the reimbursement amounts from Medicare.

For the commercial payers, the only way to get this information is by contacting your regional representative and asking them to send you the policy documents and CPT code reimbursement rates. This task can be challenging but highly recommended prior to enrolling commercial payer patients in the remote therapeutic monitoring program. The same advice applies to Medicare secondary insurance policies. Medicare advantage plans are required to cover RTM services to the amount listed on the Medicare website above.

Read More: Physician Fee Schedule Guide – cms.gov

EMR Submissions of Codes

Once your HEP/RTM software produces the CPT codes to be submitted at the end of the calendar month, another challenge that will present itself is how to submit the CPT codes. Since these CPT codes have a unique behavior compared to traditional CPT codes, it is often confusing and challenging to use your existing electronic health record system to submit these codes since they are not considered a visit and do not require a traditional SOAP note format. There are two common scenarios that most clinics adopt.

Scenario 1 – Submitting the RTM CPT codes in an existing daily note for the patient. This option works great for patients who are still receiving care in the clinic. You can simply do your normal daily note and then add the RTM CPT codes from the previous month and place them into that daily note. This does not work well for the last month of CPT codes submissions because the patient has most likely been discharged from your care and there is not a daily note to do because the patient has been discharged.

Scenario 2 – Creating an RTM Visit Type. This is the scenario that I have to follow due to my EMR system. Creating a unique visit type, scheduling the visit on a day following the end of the previous month that does not fall on the same day as a normal daily visit for the patient. We have chosen to pick a date of service that is the first Saturday of each month to avoid duplicate claims submissions because we don’t see patients on the weekends. Remember there is no date of service associated with these CPT codes like we normally have since it’s a month’s worth of monitoring services that have accumulated and then been produced at the month’s end. Then arriving at the RTM visit and entering in the codes for RTM with the amount of time and the provider who was associated with the production of the codes. The SOAP note section, although not required, I have chosen to enter information that I believe makes the most sense for compliance. Items discussing the setup and education of the device, is the patient compliant with the home program, have there been any changes to the plan of care due to RTM data. The final step is to send the RTM Visit type for signing by the supervising therapist, since in my situation a physical therapy assistant provides the monitoring time and needs a cosigner when submitting.

This part is always overwhelming in the beginning, but once you identify your process and procedure, it will surely get easier as time goes on. I would highly recommend contacting your EMR company and telling them what your goals are and asking them to provide you with any documentation they might have that will help make this process easier.

How are these CPT codes Unique?

RTM CPT Codes have several elements that behave differently than normal CPT codes. The following is a list of those items to consider:

• Not a visit – RTM CPT codes are not considered a visit and are defined as “sometimes therapy”. This means that there is no defined date of service since the codes are cumulative throughout an entire month of service. This also means that the submission of these codes should not count against your visit counts for authorizations or progress note due dates. However, both the EMR system and Medicare require a date of service to be applied to the code to avoid a denial. Makes no sense but it is the way it currently is. Since a date of service is required by Medicare and also denials will occur if you submit multiple submissions on the same day, I have adopted the system of submitting these codes on the first Saturday of each month.
• No Copay – Since the CPT Codes for RTM are not considered a visit, there is also not a copay that is to be attached to these claims. It’s important to check with your EMR system and find out how this is possible. In my EMR system, it’s not possible and my billing specialist has to remove the copays for each claim submission, which is not ideal. Most EMR companies that have a specific RTM visit type have removed the visit count and copay requirements for these types of visits.
• No SOAP Note Required – The supporting documentation requirements for RTM are from the onset of the plan of care document stating the frequency, duration, and justification for why you will be doing remote monitoring. There is no requirement for a SOAP note since this is not a visit. The supporting documentation of your monitoring time should be available in the software program that you are using, which accounts for every minute of monitoring time and what was done; this does not need to be included in a SOAP note format but does need to be available upon request from the insurance company.
• PTA Reduction – For the first two codes 98975 and 98977, since they are software-based codes for setup and education and device supply, there is no reduction of reimbursement if a PTA is involved with the case of monitoring. For codes 98980 and 98981, these are time-based, and it does matter which type of provider was involved in the monitoring activity. If a PTA was involved for the majority of the 20 minutes for each code, then a CQ modifier needs to be attached to the code upon submission in order to process the 15% reduction from Medicare.
• Place of Service – The place of service is something that is confusing and not clarified by Medicare. Technically, remote monitoring is not telehealth and could be done while the provider is in the clinic or at home. In my private practice, we use a normal place of service and haven’t run into any issues. In other practices, the reason for denial has been the place of service not being telehealth. This is something that you will simply have to experiment with.

Challenges Encountered

In my experience billing for RTM services now for almost two years and working with many other clinics around the country, there have been many challenges that have come up that I want to share with you in the hopes that you can avoid these challenges as you start your RTM journey.

• 30 days between submissions – As mentioned earlier, each code has either a 30-day period before the code can be submitted or a calendar month needs to be completed before the codes can be submitted. The best way I have found to not have to think about this is to simply submit all the codes after the end of each month has occurred. Once you select your submission date, it’s important to make sure your next month’s submission date is at least 30 days following; otherwise, you will receive a denial for the code 98977 because it can only be billed every 30 days.
• Duplicate submissions will result in denial – If you submit the CPT codes for RTM on the same day as a normal daily visit, one of the submissions will be denied because it will be considered a duplicate submission. This is why I recommend selecting a day of submission or date of service as the first Saturday of the month to avoid this.
• Advantage plans as secondaries pay but some commercial secondaries don’t – Most patients with Medicare have a secondary insurance plan. It’s been our experience that Medicare Advantage plans cover the RTM CPT codes but Commercial secondary insurances are hit or miss. So far we have seen complete denials of RTM CPT codes from Champa, VA, Federal Blue Cross Blue Shield, and Tricare. I would highly encourage you to reach out to your secondary plans to find out more information.
• Commercial Plans that Cover RTM – So far Medicare, BCBS, and United Health are the commercial payers who have policy documents that cover most patients for RTM in most states. There are exceptions which can be seen here in the most recent AMA document. It seems to be too early for the commercial payers but it’s worth investigating if RTM services are covered in your area.
• Delays in AR – Due to the rules of these codes requiring a calendar month to end or 30 days to pass before submitting the codes, it’s obvious that there will be a larger length of time before you get paid. I would plan for at least 45 days from the date of submission.
• Patient responsibility – Since Medicare pays for RTM and some secondary insurances don’t, it’s important to decide how you are going to handle the potential remaining 20% balance from these codes. If you are going to pass this along to the patient, it’s important to educate the patients beforehand so that they are not confused and frustrated months later when receiving a statement from your office. I personally pass this cost to the patient but take extra steps to educate the patient on their first day of service about what to expect.
• Date of Service on EOB – Since these codes do not have a date of service and also can’t be submitted until the month’s end, the patient when receiving an EOB from the insurance company sometimes 30 days after their last visit will see a claim submission date that does not align with their visit dates in the clinic. This naturally will spark the phone call from the patient stating that they were not in your clinic on that date of service. This can make the patient feel like they are being scammed. It’s important to be prepared for this inevitable conversation and reassure them that indeed they were not in your clinic on that date but the insurance rules require them to enter an arbitrary date upon submission.
• Requests for Supporting Documentation – My personal experience working with BCBS of Michigan has been interesting. They have a current process that requires all RTM CPT codes to be first denied, then a form submitted with supporting documentation regarding RTM. In our case, this documentation is simply the signed plan of care that states the frequency, duration, and justification of why we are monitoring this patient and then signed off by the physician. This process adds time to getting paid and is frustrating. To compound that the insurance company inevitably doesn’t receive faxes or simply files the documents without sending to the medical reviewer which adds a requirement for us to call the payer to confirm they have received the requested documentation. This is not a common situation but demonstrates what is accepted as supporting documentation, it’s the plan of care, not the log of monitoring time.