Senior woman participating in a medication adherence program

In 2022, medical professionals—from solo practitioners to physical therapists to major health systems—have new reimbursement opportunities in remote therapeutic monitoring (RTM). Five new codes finalized by the Centers for Medicare & Medicaid Services (CMS) in the 2022 Medicare Physician Fee Schedule (PFS) final rule went into effect on January 1, 2022.  At first glance, the structure of these new RTM codes is strikingly similar to earlier remote physiologic monitoring or RPM codes: there are payments for a one-time patient set up on a device, for supplying the device itself, and for monthly monitoring and patient care management. But a deeper look reveals the impact on medication adherence programs.

What is RPM?

Let’s start with the set of codes that clinicians are already familiar with: RPM. Often called “remote patient monitoring,” RPM is an umbrella term used for a variety of remotely delivered care activities. But the statutory RPM term stands for “remote physiologic monitoring,” indicating that RPM concerns what the body’s physiology communicates. 

RPM permits on-body (or in-body), FDA-defined medical devices to passively and automatically report physiologic readings to clinicians. Such readings might include the patient’s temperature, blood pressure, blood glucose level, or weight. Providers monitoring these devices can use the data to inform patient care. For example, providers might examine readings to ensure a patient is sticking to a care plan, maintaining weight, or keeping their blood pressure within a reasonable range. 

CMS introduced RPM billing codes in the 2019 Physician Fee Schedule (PFS), allowing providers to be reimbursed not only for care management services related to remote patient data but for the device itself and time spent coaching patients on appropriate usage. The codes were eventually clarified to include monitoring of all diseases and conditions.

What is RTM?

Since the RPM codes were launched in 2019, digital health has become more widely accepted, and CMS has matured in its understanding of remote monitoring. Recognizing that RPM did not include some important use cases for remote care, CMS announced the introduction of remote therapeutic monitoring, or RTM codes, on November 2, 2020, to further enhance remote care delivery. In its proposal, CMS described RTM codes as follows: 

RTM codes monitor health conditions, including musculoskeletal system status, respiratory system status, therapy (medication) adherence, and therapy (medication) response, and as such, allow non-physiologic data to be collected. Reportedly, data also can be self-reported as well as digitally uploaded. 

In short, while RPM covers solely physiologic status, RTM covers patients’ ongoing therapeutic status: adherence to therapy between office visits, be it medication adherence or physical therapy with specific allowance for the use of self-reported data. Put another way, RTM provides support for patients to show or tell providers how they are adhering to their prescribed therapy and how their body is responding in between office visits. For example, RTM allows for patients to not only report if they’ve taken medication but also how their pain levels change in response to their medication.  RTM’s inclusion of patient self-reported data is a major reason why RTM is likely to increase engagement among a wide range of individuals. 

While RTM reimbursement is still brand-new, virtual programs in medication adherence, physical therapy, pain management, and respiratory care are well established. For example, multiple case studies have proven the value of video directly observed therapy (VDOT) for medication adherence programs for conditions such as asthma, hepatitis C, diabetes, substance use disorder, and tuberculosis.

Who Can Bill for RTM vs. RPM?

One of the greatest differences between RPM and RTM lies in which health professionals can bill for these services. CMS categorizes RPM codes under evaluation and management (E/M) CPT codes, which can be billed by physicians or non-physician practitioners, such as physician assistants, and several different types of advanced practice nurses.

Unlike the RPM codes, RTM codes are categorized under “general medicine” and can be ordered and billed by a wider range of qualified healthcare practitioners (QHPs) who otherwise cannot independently order and bill for E/M services. These qualified healthcare practitioners include occupational therapists, physical therapists, psychologists, nutrition professionals, licensed clinical social workers, and many others. RTM creates a new opportunity for these types of practitioners to monitor patients for their adherence to diet, nutrition, physical therapy regimens, medication, and many more therapeutic interventions. RTM greatly widens the pool of providers eligible to deliver and bill for care in 2022. 

Applying RTM in Practice

Currently, the 2022 RTM “supply of device” codes (CPT code 98976 and CPT code 98977) only cover musculoskeletal (MSK) and respiratory devices, but CMS has indicated that it is considering expanding the eligible device categories. Yet, three of the five new RTM codes provide reimbursement opportunities for any condition, and we encourage eligible clinicians to begin incorporating RTM into their practices now.

New RTM Code

CMS Name

Eligible Use Cases

CPT 98975 Initial Set-up and Patient Education Musculoskeletal system status, respiratory system status, medication adherence, medication response
CPT 98976 Supply of Device for Monitoring Respiratory System Musculoskeletal system status, respiratory system status, medication adherence, medication response
CPT 98977 Supply of Device for Monitoring Musculoskeletal System Musculoskeletal system status or respiratory only 
CPT 98980 Monitoring/Treatment Management Services, first 20 minutes Musculoskeletal system status or respiratory only
CPT 98981 Monitoring/Treatment Management Services, each additional 20 minutes Musculoskeletal system status, respiratory system status, medication adherence, medication response

Source: 2022 Medicare Physician Fee Schedule (PFS) final rule

In its proposal of the 2022 RTM codes outlined in the table above, CMS specifically called out medication adherence as a use case already in practice among providers. As our CEO Sebastian Seiguer said in a recent interview published in Healthcare IT News, “Monitoring and improving medication adherence is one of the lowest hanging fruit in all of healthcare when it comes to improving patient outcomes.” Michael Dalton, vice president of virtual care enterprise at MetroHealth, shared on a webinar hosted by Becker’s Healthcare that the new RTM codes will allow his organization’s chronic pain management clinic to remotely assess patient pain levels through direct feedback and intervene before it becomes an emergency. Additionally, the new codes will allow MetroHealth to be proactive in ensuring that patients requiring inhalers are compliant and properly utilizing their medication at home through video Directly Observed Therapy (DOT). Other potential applications of RTM beyond MetroHealth’s examples include virtual physical therapy, closer diabetes management, or even capturing mood related to mental health treatment.    

While the possibilities aren’t endless in RTM, they are vast. Providers looking to innovate and create more continuous relationships beyond the office should investigate how RTM can help. Not only is it a new revenue stream in 2022, but more importantly, it’s a proven method of improving outcomes for those who matter most—the patients.

Learn about emocha Health’s reimbursable medication adherence program