The final 2022 Medicare Physician Fee Schedule (“2022 MPFS”) released on November 2, 2021, created a new family of five CPT codes for Remote Therapeutic Monitoring (“RTM”) and RTM Treatment Management services, which resemble the services and code structure of the codes used for RPM.
The Remote Therapeutic Monitoring code set may provide additional reimbursement opportunities for HealthSnap’s customers. Importantly, CMS noted in the 2022 MPFS that although there are similarities between RTM and RPM, there are two primary differences: (1) the RTM codes, unlike the RPM codes, have not been designated as “care management services” and therefore the clinical labor component of the codes must be provided under the direct supervision of the billing practitioner (instead of general supervision), and (2) RTM non-physiologic and therapeutic data can be patient self-reported, as well as digitally uploaded, while RPM requires that data be physiologic and digitally uploaded.
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.
What Are the Remote Therapeutic Monitoring (RTM) CPT Codes?
The 2022 MPFS described each of the RTM codes as follows:
CPT code 98975 (*$19)
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 (*$55)
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 (*$55)
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 (*$50)
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 (*$40)
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.
*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.
Key Requirements for Billing CPT Codes 98975, 98976, 98977, 98980, and 98981
According to the 2022 CPT Code Manual, CMS requires the following to bill for RTM services:
General
Medical Device
Devices used for RTM services, just like for RPM services, must be a “medical device” as defined by the FDA FD&C Act. The FDA defines “medical device” as “an instrument, apparatus, implement, machine, contrivance, implant, in vitro reagent, or other similar or related article, including a component part, or accessory which is . . . intended for use in the diagnosis of disease or other conditions, or in the cure, mitigation, treatment, or prevention of disease . . .”.
This does NOT mean that a device used must necessarily go through the FDA “clearance” or “approval” process for reimbursement purposes, but the FDA may require this depending on the device’s status under applicable FDA pathways. This means that the device would either need to be subject to current FDA “enforcement discretion”, registered, cleared via 510(k) submission, or approved via a PMA application. Importantly, the FDA’s definition of a “medical device” also includes SaMD.
Data
RTM data can be patient-reported or automatically transmitted through the RTM device(s).
Billing Practitioner
Providers who are eligible to bill Medicare directly for their services and whose scope of practice includes RTM services are eligible to order and 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.
*RTM treatment management services (CPT codes 98980 and 98981) can be furnished by therapists who are working in rehabilitation agencies and CORFs, but not when a patient is inpatient in a hospital or SNF.
CPT Codes 98980 & 98981
Live, Interactive Communication
CPT codes 98980 and 98981 both require at least one interactive communication with the patient or caregiver during the calendar month. In the 2021 MPFS, CMS clarified that “interactive communication” refers to “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.”
No Duplicative Concurrent Billing
CPT codes 98980 and 98981 can be billed in conjunction with the following:
- CCM codes 99487, 99489, 99490, 99491, 99437, and 99439;
- PCM codes 99424, 99425, 99426, and 99427;
- TCM codes 99495 and 99496; and
- BHI services codes 99484, 99492, 99493, and 99494.
However, the billing practitioner cannot count the same period of time for more than one code, and no time can be counted on a day when the billing practitioner reports an E/M service for the same beneficiary.
RTM and RPM should not be billed for the same patient in the same month. The American Medical Association’s 2022 CPT Professional (“2022 CPT Manual”) states that 98980 should not be reported in conjunction with 99457.
The 2022 CPT Manual states that CPT codes 98980 cannot be reported in the same calendar month as CPT code 99091.
CPT Codes 98975, 98976, and 98977
CPT Code 98975
Use this code to report setup and patient education on the use of the device(s) that will be used to monitor their therapeutic or non-physiological data.
CPT code 98975 may only be reported once per episode of care. For purposes of RTM, an “episode of care” begins when the service is initiated and ends when targeted treatment goals are attained.
Do not report when the time spent providing the respective services is included in the time spent for other RTM codes (e.g. 98980).
CPT Codes 98976 and 98977
CPT codes 98976 and 98977 may only be billed when there are at least 16 separate days of data readings transmitted to the provider in the relevant 30-day period.
CPT codes 98976 and 98977 can be billed once each 30-day period, regardless of the number of devices supplied to the patient.
CPT code 98976 is used to report supply of a connected device or devices that monitor the respiratory system.
CPT code 98977 is used to report supply of a connected device or devices that monitor the musculoskeletal system.
CPT Codes 98975, 98976, and 98977
Codes can be reported in conjunction with devices that will be used for CPT codes 98980 and 98981.
Do not report 98975, 98976, 98977 with other physiologic monitoring services (e.g., 99453 and 99454).
Remote Therapeutic Monitoring (RTM) Billing Considerations
Incident-To Billing of Clinical Staff Under CPT Codes 98980 and 98981
A clinical staff member is defined in the CPT Manual as “a person who works under the supervision of a physician or other qualified health care professional and who is allowed by law, regulation, and facility policy to perform or assist in the performance of a specified professional service, but who does not individually report that service.” This means that the type of personnel that qualify as “clinical staff” for purposes of RTM varies by state law and providers should look to the applicable scope of practice laws in the patient’s state to determine who can and cannot provide monitoring services.
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. “Direct Supervision” [KO1] means the billing practitioner must be in the same physical office location as the clinical staff and must be immediately available to provide assistance when necessary. The following practitioners’ benefits allow for billing incident-to their professional services and can therefore utilize clinical staff in the provision of RTM where appropriate: Physicians, Physician Assistants, Nurse Practitioners, Clinical Nurse Specialists, Certified Nurse Midwifes, and Clinical Psychologists. Note that there are additional limitations (discussed below) for billing RTM services incident-to under a therapy plan of care. 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.
Note that when billing incident-to for physical, occupational, and speech language therapy services, CMS requires clinical staff to be, at least, a graduate of a program of training for physical therapy, occupational therapy, or speech-language pathology. This does not apply for physical therapists and occupational therapists billing for the time of physical therapy and occupational therapy assistants (“PTA/OTA(s)”) because incident-to is not the mechanism used for billing the time of the PTAs or OTAs.
Care Management Services Designation
Unlike RPM CPT codes 99457 and 99458, CMS did not designate CPT codes 98980 and 98981 as “care management services”. This means that when RTM services are provided incident-to the billing practitioner, clinical staff must be supervised under direct supervision, meaning the billing practitioner must be in the same physical office location as the clinical staff. 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.
Understand and Leverage RTM CPT Codes With Remote Therapeutic Monitoring Powered By HealthSnap
CMS’s recent announcement of the Remote Therapeutic Monitoring (RTM) code set provides additional reimbursement opportunities for our HealthSnap customers. The RTM codes are similar to the existing RPM codes, but with a few key differences that providers need to be aware of. To schedule a demo and learn more about how HealthSnap can help you leverage the RTM codes and improve care plans for your patient population, click here!
