On November 2, 2021, the Centers for Medicare & Medicaid Services (CMS) published the Medicare Physician Fee Schedule for 2022. Within the Final MPFS 2022, CMS approved five new billing codes for services associated with Remote Therapeutic Monitoring (RTM). These codes provide a new way for medical professionals to be compensated for continuous patient engagement.
This is an exciting development, as it is the first time CMS has explicitly encouraged monitoring medication adherence.
For people watching the virtual care space, RTM codes are seen as an extension of Remote Physiological Monitoring (RPM) codes. However, the codes are quite different – as explained below.
But because these codes are so new, attorneys, health systems, providers and medical device companies are still figuring out how and where they can be used. Here’s what we know so far.
What is Remote Therapeutic Monitoring?
RTM codes allow providers to be reimbursed for monitoring – in technical terms – “therapeutic” or “non-physiologic” patient data, such as “musculoskeletal system status, respiratory system status, therapy (medication) adherence, and therapy (medication) response.” Over the past eighteen months, CMS has clarified “physiologic” data as data automatically collected and transmitted from devices, excluding any self-reported or self-recorded data.
While CMS’ definition of “non-physiological data” has not been fully detailed, the agency has explained that RTM allows for patient self-reported data. This data might include, we imagine, patient-generated videos, photos, patient narratives, and other types of patient self-reported information.
How do the new codes support RTM?
Medicare has said that it will reimburse providers for three activities:
- Setting up patients with the device or software and explaining how it is used.
- Ongoing fees associated with renting or subscribing to the RTM software or device.
- The first and second 20-minute increments of delivering care remotely each month, which includes monitoring patient data and at least one live interaction, such as a live video visit or phone call.
How is Remote Therapeutic Monitoring (RTM) different from Remote Patient Monitoring (RPM)?
RPM concerns the automatic transmission of patient physiologic data (heart rate, blood pressure, weight, oxygen level) to the provider via a device. As we wrote above, remote therapeutic monitoring, by contrast, concerns data related to therapy adherence, therapeutic response, and health condition status which is non-physiologic. Data can also be self-reported, presumably using hardware or software will also be allowed under RTM.
Another important difference between the two lies in who can order and bill the services. RPM services can be delivered by Qualified Healthcare Professional (QHCPs) such as physicians, physicians’ assistants, nurse practitioners, certified nurse midwives, and CRNAs, as well as their clinical staff (medical assistants, licensed nurses) under direct or general supervision.
As written today, RTM is more expansive than RPM in who can bill, including QHCPs who do not typically bill for RPM. These practitioners include physical and occupational therapists as well as speech therapists. However, CMS was not clear whether these practitioners could bill for using clinical staff.
What’s next for Remote Therapeutic Monitoring?
CMS is considering adding a general device code to the new RTM codes. This new code would allow for use of devices beyond those that monitor the respiratory or musculoskeletal systems. CMS has also stated that the use of clinical staff by billing practitioners is being considered and will be discussed imminently with relevant stakeholders such as the American Medical Association.
As CMS stated in the 2022 MPFS, “We hope to continue to engage in dialogue with stakeholders, including the AMA CPT, in the immediate future on how to best refine the coding…”