What is Remote Therapeutic Monitoring (RTM)?
Recently the Centers for Medicare and Medicaid Services (“CMS”) in its Proposed Medicare Physician Fee Schedule for 2022 (the “Proposed Rule”) mentioned new codes for monitoring for the management of patients using medicals devices that collect non-physiological data.
Although non-physiologic data has yet to be fully defined by CMS, the proposed rule notes that RTM would be used to monitor a range of health conditions and patients that stand to benefit from remote monitoring outside of the traditional confines of tracking vitals data.
Examples of potential non-physiologic data given by CMS include musculoskeletal system status, respiratory system status, therapy/medication adherence, and therapy/medication response.
How will RTM differ from RPM (Remote Patient Monitoring)?
There was some clarification on how CMS expects RTM and RPM to differ. To summarize the three notable differences:
- Provider types that cannot bill for RPM now may be able to bill for RTM,
- RTM data can be collected from medical devices that measure non-physiological data, such as those used to support medical adherence and medication symptom/adverse reaction applications.
- RTM, as defined, would cover data self-reported by patients if the code requirements are met. This difference has prompted CMS to request feedback on devices for RTM
Here’s how RTM might function. An older patient with multiple chronic conditions is provided a “smart” inhaler to remind the patient when to take their medications. The inhaler includes technology that informs the patient’s primary care provider whether medications were taken at their appropriate time. The provider can monitor this non-physiologic medication adherence data, or data that is self-reported by the patient, to assess the effectiveness of the inhaler in helping the patient maintain adherence. If the patient is struggling, the provider can explore other solutions to help improve adherence to the medication regimen. Since the inhaler is not collecting physiological vital signs, it cannot be billed under RPM, but may be billable under RTM.
What will be the new CPT Billable codes ?
The RTM code descriptions are as follows:
- CPT code 989X1 (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 989X2 (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 989X3 (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 989X4 (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 989X5 (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 (List separately in addition to code for primary procedure)
What are we waiting for before this becomes official?
According to the Physician Fee Schedule, these new codes will be released on January 1 2022. However, there are a few items that need to ironed out:
Type of practitioners who can bill
Currently we assume that QHCPs such as physical therapists, occupational therapists, clinical psychologists, registered dieticians, and other practitioners can order and bill for RTM under the codes as currently proposed.
Will RTM Billing require Physician and NP time for reimbursement?
This was a big sticking point for RPM initially because it was thought that Physician time with patients was directly required for reimbursement. Once CMS allowed for the RPM codes as care management services subject to general supervision when ordered by a physician and/or NPP, this allowed RPM to take off. We hope the same for the propose rule.
Conclusion
The world of Remote Monitoring is looking to expand rapidly over the next few years. It is in the best interest of all healthcare organizations to get fully versed in where the industry is going. We hope SynsorMed can help in that education.
To learn more about how SynsorMed can help with your CCM, RPM and RTM needs please reach us at info@synsormed.com
