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

March 20, 2023

What Is Remote Therapeutic Monitoring?

Remote therapeutic monitoring refers to the use of technology to monitor patients’ health status and treatment progress outside of traditional healthcare settings. This type of monitoring allows healthcare professionals to remotely collect data on patients’ vital signs, medication adherence, and other important health metrics, and use this information to adjust treatment plans as necessary. Remote therapeutic monitoring can be particularly beneficial for patients with chronic conditions, as it allows for more frequent and timely monitoring of their health, potentially improving outcomes and reducing healthcare costs. Examples of remote therapeutic monitoring technologies include wearable devices, mobile health apps, and telemedicine platforms.

 

Who is Qualified to do the monitoring?

A Licensed physical therapist or physical therapist assistant are both qualified to provide remote patient monitoring.

 

What are the benefits to a physical therapist or physical therapy clinic by using remote therapeutic monitoring?

The two main benefits are increasing patient outcomes which studies already show that the increase in function and reduction in pain improve by roughly 25%. The second benefit is financial. The range for increasing the revenue per patient per month is roughly $150. For the entire plan of care the profit increase ranges from 49-135% per patient using RTM.

 

What type of devices are approved?

Wearable sensors and activity trackers that can measure movement and provide feedback on physical activity levels.

In-home monitoring systems that can track vital signs such as heart rate, blood pressure, and oxygen saturation.

Remote monitoring platforms that allow physical therapists to monitor patient progress and provide feedback through telehealth or video conferencing technology.

Virtual reality systems that can be used for rehabilitation exercises and to improve range of motion and motor function.

 

What are the CPT codes that describe RTM and what is the description of each of the new RTM CPT codes?

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

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.
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.
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.
98978
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 cognitive behavioral therapy, each 30 days
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.
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; each additional 20 minutes (List separately in addition to code for primary procedure).

 

What is the difference between the Remote Therapeutic Monitoring (RTM) codes and the existing Remote Physiological Monitoring (RPM) codes?

Per the American Medical Association’s “CPT Changes 2022: An Insider’s View“, on page 178, the AMA states that the main difference is “RPM codes are intended to monitor physiologic parameters such as weight, blood pressure, pulse oximetry, etc while the RTM codes are intended to monitor services (musculoskeletal system status, respiratory system status, therapy adherence and therapy response) representing the review and monitoring of date related to signs, symptoms, and functions of a therapeutic response”.

 

Can physical therapists (PTs), occupational therapists (OTs) and speech-language pathologists (SLPs) bill the RTM codes to Medicare and other insurance carriers and be reimbursed for them?

In the Centers for Medicare and Medicaid Services (CMS) calendar year 2022 final rule for services reimbursed under the Medicare Physician Fee Schedule (MPFS), CMS reversed their previous position that they outlined in the proposed rule and will allow physical therapists, occupational therapists and speech-language pathologists to bill and be reimbursed for the RTM CPT codes. CMS also clarified that a physical therapist assistant (PTA) under the direct supervision of a physical therapist and an occupational therapy assistant (OTA) under the direct supervision of an occupational therapist could furnish the RTM services.

 

What types of practices and organizations will be able to bill the RTM codes?

Per the Centers for Medicare and Medicaid Services (CMS) Transmittal 11118, CMS states the RTM services can be provided by therapists in private practice, or facility-based therapists. Facility-based settings would include Comprehensive Outpatient Rehabilitation Facilities (CORFs), Rehabilitation Agencies, Skilled Nursing Facilities doing Part B, Home Health Agencies doing Part B in the home and Hospital outpatient therapy departments.

 

Will the Annual Therapy Threshold and Multiple Procedure Payment Reduction Policy apply to the RTM codes?

CMS is designating the RTM codes as “sometimes therapy” codes which means when provided under an outpatient therapy plan of care, these services will count towards the annual therapy dollar threshold but the Multiple Procedure Payment Reduction (MPPR) policy will not apply. Since these codes will apply to the annual therapy threshold, they will require the discipline specific modifier be appended to them on the claim form (e.g., GN, GO, GP) when provided under an outpatient therapy plan of care.

 

If the RTM codes are provided in whole or in part by a physical therapist assistant (PTA) or an occupational therapy assistant (OTA), will the codes require the CQ/CO modifier and therefore, 15% reduction apply?

The di minimis standard will apply to CPT code 98975, 98980 and 98981 if provided in whole or in part by a PTA or an OTA but the di minimis standard will not apply to CPT codes 98976 and 98977. This means the CQ/CO modifier will be required on CPT code 98975, 98980 and 98981 if provided in whole or in part by a PTA or an OTA.

 

How much will CMS reimburse for each of the new remote therapeutic monitoring CPT codes?

For the payment amounts, I used the National Payment average per the Centers for Medicare and Medicaid Services.

 

What CPT codes can be the same day as the RTM codes?

According to the National Correct Coding Initiative (NCCI) edits, Version 28.0, effective with dates of service January 1, 2022 – March 31, 2022, CMS will not reimburse for CPT code 97750 (Physical performance test or measurement) on the same date of service a provider also bills either CPT code 98980 or 98981. To access the latest version of NCCI edits, click HERE.

 

What type of device can I use in order to bill CPT codes 98975, 98976 and/or 98977?

Per the American Medical Association’s “CPT Changes 2022: An Insider’s View“, on page 177, it states “To report 98975, 98976, 98977, the device used must be a medical device as defined by the FDA”.

Per Section 201(h) of the Food, Drug, and Cosmetic Act, a device is:

No! Per the American Medical Association’s “CPT Changes 2022: An Insider’s View“, on page 177, it states “Codes 98975, 98976, 98977 are not reported if monitoring is less than 16 days”. An instrument, apparatus, implement, machine, contrivance, implant, in vitro reagent, or other similar or related article, including a component part, or accessory which is: recognized in the official National Formulary, or the United States Pharmacopoeia, or any supplement to them, intended for use in the diagnosis of disease or other conditions, or in the cure, mitigation, treatment, or prevention of disease, in man or other animals, or intended to affect the structure or any function of the body of man or other animals, and which does not achieve its primary intended purposes through chemical action within or on the body of man or other animals and which does not achieve its primary intended purposes through chemical action within or on the body of man or other animals and which is not dependent upon being metabolized for the achievement of its primary intended purposes. The term “device” does not include software functions excluded pursuant to section 520(o).

 

I see that CPT codes 98976 and 98977 at the end of their description each state “each 30 days”. Must I do the remote therapeutic monitoring for the entire 30 days to bill CPT codes 98976 and/or 98977?

No! Per the American Medical Association’s “CPT Changes 2022: An Insider’s View“, on page 177, it states “Codes 98975, 98976, 98977 are not reported if monitoring is less than 16 days”.

 

I see that CPT code 98980 states “first 20 minutes”. Can I bill this code if I spend less than 20 minutes in a calendar month?

No! Per the American Medical Association’s “CPT Changes 2022: An Insider’s View“, on page 178, it states “do not report 98980, 98981 for services of less than 20 minutes”.

 

I see that CPT code 98981 states “each additional 20 minutes”. Can I bill this code if I spend less than an additional 20 minutes in a calendar month?

No! Per the American Medical Association’s “CPT Changes 2022: An Insider’s View“, on page 178, it states “do not report 98980, 98981 for services of less than 20 minutes”. This means to bill 1 unit of CPT code 98981 in a calendar month, you would need to spend 40 minutes providing 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. For the first 20 minutes, you would bill 1 unit of 98980 and then for the next 20 minutes, you would bill for one unit of 98981. To bill 2 units of 98981 during a calendar month, you would need to spend 60 minutes providing 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.

There is no substantial portion of time with CPT codes 98980 and 98981. You must do the entire 20 minutes.

 

Will Medicare Advantage plans and commercial insurance carriers reimburse the RTM codes if provided and billed by physical therapists, occupational therapists and speech language pathologists?

That will be insurance carrier and plan specific and you, the provider, would need to check.

Will Medicare Advantage plans and commercial insurance carriers have a patient cost-sharing responsibility on the RTM codes (e.g., co-pay or co-insurance)?

That will be insurance carrier and plan specific and you, the provider, would need to check.

 

In order to bill CPT codes 98976 and/or 98977, must I supply the medical device that captures the recordings and/or programmed alert(s) transmission to monitor the respiratory system or musculoskeletal system?

Yes, you must be the one to supply the medical device that captures the recordings and/or programmed alert(s) transmission to monitor the respiratory system or musculoskeletal system. If the patient is using their own FDA medical device or obtains the medical device from another provider, you would not bill CPT code(s) 98976 or 98977.

 

To meet the interactive communication requirement for CPT codes 98980 and 98981, in what formats can the interactive communication occur?

It is our understanding that the interactive communication requirement for CPT codes 98980 and 98981 can be met by a phone call (audio only) or a video call (audio and visual).

Per the 2021 Final Rule for Services Reimbursed under the Medicare Physician Fee Schedule, CMS stated “Stakeholders have requested that we define “interactive communication” as used in the code descriptors for CPT codes 99457 and 99458. We explained in the proposed rule that we saw this remote, non-face-to-face exchange as being similar to the exchange that occurs in providing services described by HCPCS code G2012, Brief Communication Technology-Based Service, which we finalized in the CY 2019 PFS final rule (83 FR 59483 through 59486). We clarified that “interactive communication” for purposes of CPT codes 99457 and 99458 involves, at a minimum, a real-time synchronous, two-way audio interaction that is capable of being enhanced with video or other kinds of data transmission.

Even though this definition was for remote physiologic monitoring, the same definition would apply for remote therapeutic monitoring.

 

To meet the interactive communication requirement for CPT codes 98980 and 98981, can this be met by the therapist or therapist/therapy assisting communicating with the patient via text or email?

It is our understanding that the interactive communication requirement for CPT codes 98980 and 98981 can be met by a phone call (audio only or a video call (audio and visual).

Per the 2021 Final Rule for Services Reimbursed under the Medicare Physician Fee Schedule, CMS stated “Stakeholders have requested that we define “interactive communication” as used in the code descriptors for CPT codes 99457 and 99458. We explained in the proposed rule that we saw this remote, non-face-to-face exchange as being similar to the exchange that occurs in providing services described by HCPCS code G2012, Brief Communication Technology-Based Service, which we finalized in the CY 2019 PFS final rule (83 FR 59483 through 59486). We clarified that “interactive communication” for purposes of CPT codes 99457 and 99458 involves, at a minimum, a real-time synchronous, two-way audio interaction that is capable of being enhanced with video or other kinds of data transmission. Even though this definition was for remote physiologic monitoring, the same definition would apply for remote therapeutic monitoring.

 

Must the therapist or therapist/therapy assistant be licensed in the state where the patient resides to bill CPT codes 98980 and 98981?

Yes! The physical therapist, physical therapist assistant, occupational therapist and/ or occupational therapy assistant must be licensed in the state where the patient resides in order to count minutes towards the billing of CPT codes 98980 and 98981.

 

Does the billing of the RTM code(s) on a particular date count as a visit towards the requirement of writing a Progress Report every 10 visits, at minimum?

No, since RTM is not considered a therapy visit.

 

When I do a monthly communications with the patient and they do not answer but I leave a voicemail, does this count as the communication?

No, since an interactive communication involves, at a minimum, a real-time synchronous, two-way audio interaction that is capable of being enhanced with video or other kinds of data transmission. Since you are only leaving a message and did not have a real-time two-way audio interaction with the patient, this would not count as satisfying the interactive communication requirement.