CMS proposes to cover Remote Therapeutic Monitoring

CMS proposes to cover Remote Therapeutic Monitoring

On July 13th, the Centers for Medicare and Medicaid Services (“CMS”) released its proposed Medicare Physician Fee Schedule for Calendar Year 2022 (the “2022 Proposed MPFS” or the “Proposed Rule”). Included in this announcement is the introduction of a proposed expansion of remote monitoring to include Remote Therapeutic Monitoring (RTM). Where Remote Patient Monitoring (RPM) provided additional tools for the provider to monitor physiologic readings, RTM recognized five new CPT codes for “non-physiologic” patient data such as “musculoskeletal system status, respiratory system status, therapy (medication) adherence, and therapy (medication) response” as well as pain. The new codes, part of the proposed 2022 Physician Fee Schedule, are intended to expand the scope and reach of digital health technologies to reimburse monitoring of non-physiologic data.

The creation of new RPM codes at the beginning of 2019 was a major step forward in digital health coverage to improve care delivery, outcomes, and cost management. Since that time, the American Medical Association’s (AMA) Digital Medicine Payment Advisory Group has developed, and CMS adopted, additional codes for remote monitoring services. The recent RTM proposal recognizes the benefit of remote monitoring and continues to foster the use of digital health tools to give clinicians a more comprehensive data set of their patients’ health conditions.

The structure and nature of RTM services resemble RPM services. 

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))

How Does RTM Differ from RPM?

While there are similarities between the RPM and RTM codes, CMS identified some key differences in the nature of the data collected, how the data is collected, and which clinicians are eligible to bill for RTM services.

  • The first difference is the nature of the data to be collected. RTM codes monitor health conditions including, but not limited to, musculoskeletal system status, respiratory system status, therapy adherence, and therapy response, and as such, allow non-physiologic data to be collected. Compared to RPM, the RTM codes offer the promise of broader use cases and applications in patient care. 
  • A second difference is what clinical use cases are eligible for device supply reimbursement under RTM. The two RTM device supply codes (989X2, 989X3) are similar to the RPM device supply code (99454), but not identical. 
  • A third difference is how the device collects data. Both RTM and RPM require the use of a medical device. However, according to CMS’ commentary, RTM data can be self-reported by the patient, as well as digitally uploaded via the device. 
  • A fourth difference is which clinicians can order and bill for RTM services. Based on its review of the AMA documents, CMS opined the primary billers of RTM were intended to be nurses and physical therapists. The idea being the new RTM codes would allow practitioners who cannot bill RPM codes to furnish and bill for services that look similar to those of RPM. (RPM is an E/M service and physical therapists cannot bill E/M services.) The RTM codes, accordingly, are classified as general medicine codes and not E/M codes.
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