Remote Therapeutic Monitoring Codes Incentivize Non-Physiological Monitoring

If your hospital or healthcare system uses medical devices for remotely collecting non-physiological data on your patients, there is now a new way to bill for these with the remote therapeutics monitoring (RTM) codes.  With the new codes, organizations are able to deliver high-quality remote care, and cycle back revenue from reimbursement by offering digital services.

As of January 1, 2022, hospitals and healthcare practices can seek reimbursement for remote therapeutic monitoring services under new CPT codes contained within the 2022 Physician Fee Schedule final rule promulgated by the Centers for Medicare and Medicaid Services (CMS).

To help health administrators take full advantage of this new reimbursement opportunity, this blog covers:

1. What is meant by remote therapeutic monitoring.
2. The details and requirements of the new CPT codes.
3. What kind of billing model will enable your hospital or practice to obtain reimbursement for these codes.

What Is Remote Therapeutic Monitoring?

A better question might be, “What does CMS mean when they refer to ‘remote therapeutic monitoring’?”

Unfortunately, CMS does not provide a definition of this phrase, instead drawing two main distinctions between CPT codes relating to remote patient monitoring and those covering remote therapeutic monitoring.

The first distinction is that CMS projects that the primary billers of its five remote therapeutic monitoring codes will be physiatrists, nurse practitioners, and physical therapists.

The second distinction is that, whereas the remote patient monitoring codes collect physiological data, the data collected during remote therapeutic monitoring is non-physiological data and can be patient reported. 

What does CMS mean by physiological and non-physiological? Isn’t all patient data physiological in origin?

CMS is using the term “physiological” in the way that medical doctors use it to refer to objective measurements (such as heart rate, body temperature, etc.), as opposed to the common understanding of the term, which is “of or relating to physiology.” 

Under the common understanding of the term “physiological,” pain would be physiological data because the sensory experience of pain has a physiological origin (nerve activity, etc.). 

But under the more constrained medical definition of “physiological data” that CMS is using, a patient’s self-reported shoulder pain or difficulty breathing, even though physiological in origin, is not physiological data because it’s a subjective report rather than an objective measurement.

Other examples of non-physiological data include medication adherence information (presumably, a patient’s self-reported adherence) and medication response information, which again would be reported by the patient. 
To learn about CPT codes relating to physiological data, you can read our article on CPT Codes for Remote Patient Monitoring, which CMS also refers to as Remote Physiological Monitoring.

What are the tools of remote therapeutic monitoring and what clinical staff might use them?

Remote therapeutic monitoring tools must be FDA-approved medical devices, a point made clear in the American Medical Association’s CPT Codebook. 

It also seems likely that other clinical staff — not just physical therapists and physiatrists — might use an FDA-approved medical device that collects medication adherence and response information.

Consistent with this, CMS states that the new codes are general medicine codes, meaning that any qualified health professional can bill for them.

For this reason, it’s perplexing that CMS also states, “the primary billers of RTM codes are projected to be physiatrists, NPs, and physical therapists.” First, who is making this projection? CMS? It’s not clear from the passive-voice phrasing CMS uses.

But, more importantly, why would that be the projection, given that remote monitoring tools for medication adherence and response could be used by a variety of healthcare professionals? 

Perhaps future rules or other statements from CMS will answer these questions. 

2022 CPTs for Remote Therapeutic Monitoring: Details and Requirements

Here are the details of the five new CPT codes related to remote therapeutic monitoring: 

• CPT 98975 covers initial set-up and patient education on equipment for remote therapeutic monitoring, such as equipment that assesses respiratory system status, musculoskeletal system status, therapy adherence, and therapy response. Reimbursement is $18.82. For this code to be reimbursable, the patient must go on to use the equipment for at least 16 days in a 30-day period. This requirement is found in the CPT codebook, rather than the CMS rule.
• CPT 98976 relates to supplying a device to a patient that, every 30 days, records data (such as data about respiratory system status, musculoskeletal system status, therapy adherence, and therapy response) and/or provides alerts about the respiratory system. As with CPT 98975, providers can only seek reimbursement under this code when the equipment is used for at least 16 days within a 30-day period.
• CPT 98977 is identical to CPT 98976 except it refers to alerts about the musculoskeletal system. Reimbursement for this code and 98976 is $54.09. Likewise, reimbursement depends upon the equipment being used for at least 16 days per 30-day period.
• CPT 98980 enables reimbursement for clinical staff’s treatment of a patient who is being remotely monitored; this code covers the first 20 minutes of care during a month and provides a reimbursement payment of $48.72.
• CPT 98981 covers reimbursement for each additional 20-minute period of care of a patient who is being remotely monitored at a rate of $30.57 for each additional period. Treatment under both 98980 and 98981 requires at least one interactive communication with the patient.

Healthcare providers should also note that CPT 98975 is subject to the de minimis standard. As such, if a physical therapy assistant or occupational therapy assistant contributes more than 10% of the time devoted to setting up the remote therapeutic equipment and educating the patient on its use, the provider can only bill for 85% of the reimbursement rate of $18.82. 

In contrast, services provided by a physical therapy assistant or occupational therapy assistant that do not exceed 10% of the total time for CPT 98975 are considered so trivial as to not merit a payment reduction.

A Billing Model for Remote Therapeutic Monitoring

Given the details of these new CPT codes for remote therapeutic monitoring, how should healthcare providers and systems act to set themselves up for reimbursement success?

First, it is critical for health administrators to track time devoted to set-up of remote therapeutic monitoring tools and treatment related to these tools, including any time involved in monitoring or interpreting the data. Although reimbursement for treatment of a patient being monitored via a remote device requires an interactive communication with the patient, time spent not directly interacting with the patient, such as time interpreting the data, can count toward the 20-minute increments under the codes.

Second, as the AMA’s CPT Codebook makes clear, reimbursement for codes 98976, 98977, and 98980 depends upon the FDA-approved device collecting data for at least 16 days within a 30-day period. Given this requirement, administrators should ensure that their billing system captures when these devices are supplied and for how many days they are used.

Software platforms can help practices track the time providers devote to care tasks and how many days that remote therapeutic monitoring devices collect data.

For other tips on how to set up your hospital, practice, or healthcare facility for success in the new era of remote patient monitoring, be sure to read our guide to Everything You Need to Know About Remote Patient Monitoring.