Remote Therapeutic Monitoring (RTM) Frequently Asked Questions
Q. What are the Remote Therapeutic Monitoring (RTM) codes?
CPT code 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
CPT code 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
CPT code 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 code 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 code 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
These codes are classified as general medicine codes and not Evaluation and Management (E/M) codes.
Q: Does medication adherence monitoring qualify as RTM?
Yes, medication adherence monitoring is explicitly one of the intended purposes of the code set.
Q: What can I expect in reimbursement for each of the new codes?
- CPT code 98975 (*$18)
- CPT code 98976 (*$54)
- CPT code 98977 (*$54)
- CPT code 98980 (*$48)
- CPT code 98981 (*$39)
*Please Note: Reimbursement amounts listed represent a national average; exact reimbursement amounts vary by geographic region. Amounts are based on CMS 2022 non-facility pay rate and are subject to change.
Q: What is the difference between RTM and RPM?
Remote Patient Monitoring (RPM) is for monitoring physiological parameters such as heart rate and blood pressure using a connected device that automatically transmits data.
Remote Therapeutic Monitoring (RTM) is for monitoring therapeutic effectiveness and medication adherence. The data collected can be self-reported, and the device can be software as a medical device.
The RTM codes are classified as general medicine codes and not Evaluation and Management (E/M) codes. RPM is classified as an E/M service.
Please see RPM vs. RTM: Impact on Medication Adherence Programs
Q: Can we bill RPM and RTM on the same patient at the same time?
No. The American Medical Association’s CPT Manual (the “CPT Manual”) states that RTM and RPM should not be billed for the same patient in the same month.
Q: Can we bill CCM and RTM on the same patient at the same time?
Yes, because these services are complementary to each other. They do have different service element requirements so you must be sure to follow the time requirements and other billing rules that have been established. Medication adherence and other remote therapeutic monitoring activities are only one part of a holistic chronic care management program.
Q: Is RTM intended to be used for non-physiological data?
Yes. RTM is designed for the management of patients using medical devices that collect non-physiological data such as therapy/medication adherence (and/or response) and pain level.
Q: Who can bill Medicare directly for RTM services?
Providers eligible to bill Medicare directly for their services and whose scope of practice includes RTM services are eligible to bill for RTM services. This may include:
- Physicians
- Anesthesiology Assistants
- Certified Nurse Midwives
- Certified Registered Nurse Anesthetists
- Clinical Nurse Specialists, Clinical Social Workers
- Nurse Practitioners
- Occupational Therapists in Private Practice
- Physical Therapists in Private Practice
- Physician Assistants
- Psychologists
- Qualified Audiologists
- Speech-Language Pathologists in Private Practice
- Registered Dietitians or Nutrition Professionals
In all cases, practitioners must practice in accordance with applicable state law and scope of practice laws. See also: RPM vs. RTM: Impact on Medication Adherence Programs.
Q: Can clinical staff perform the 20-minutes of monitoring “incident to” the billing practitioner?
Yes. Although “clinical staff” is not included in the CPT code descriptors for codes 98980 and 98981, CMS clarified that when the billing practitioner’s benefit allows services to be furnished incident-to their professional services, RTM services can be provided by clinical staff under direct supervision, meaning the billing practitioner must be in the same physical office location as the clinical staff. The following practitioners’ benefits allow for billing incident-to their professional services: Physicians, Physician Assistants, Nurse Practitioners, Clinical Nurse Specialists, Certified Nurse Midwives, and Clinical Psychologists.
Q: Can emocha staff perform the work as “clinical staff”?
Yes, during the current public health emergency (PHE.) General supervision would typically be required for remote incident-to billing. HOWEVER, during the PHE, direct supervision may be provided through virtual direct supervision, meaning the billing practitioner must be immediately available by virtual means while clinical staff are providing monitoring services.
Q: How many times can you bill 98981?
98981 can be billed for each additional 20-minutes of service per month. There is no stated limit, but all billing is subject to medical necessity, and the burden of documentation is on the billing provider.
Q: What exactly constitutes “monitoring” to be able to bill for the 20 min?
The 20 minutes is based on time spent by the billing practitioner in remote monitoring of the patient’s adherence or response to therapy. At least one synchronous communication per month is required.
Q: Does reviewing data count? Or does there need to be interaction?
Yes, reviewing patient data is counted toward the 20 minutes, but at least one synchronous communication per month is also required.
Q: What is an example of a typical month of interaction that would be applicable?
Give an example or two of a typical month of interaction that would constitute the 20 min.
A patient with asthma is prescribed a controller inhaler alongside a medical device (can be software) that is used to monitor when the patient uses the inhaler, how many times during the day the patient uses the inhaler, how many puffs/doses the patient uses each time, and possibly other factors, such as symptoms of asthma, side effects of medication, or the pollen count and environmental factors that exist in the patient’s location at that time. This is non-physiologic data. The treating practitioner then uses the data to assess the patient’s therapeutic response and adherence to the asthma treatment plan. This can enable the practitioner to better determine how well the patient is responding to the particular medication, what social or environmental factors affect the patient’s respiratory system status, and what changes could be made to improve the patient’s health.
Q: What is required to bill the device codes?
- The device must be registered with the FDA or fall into a category of exemption from registration.
- A minimum of 16 data recordings per month are required to bill a device code.
Q: Does emocha’s app qualify as a device?
Yes, emocha is a Class 1 Mobile Medical Application (MMA) registered with the FDA. See also Medication Adherence Monitoring is Reimbursable.
