Updates to Remote Therapeutic Monitoring

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By Rick Gawenda, PT

Effective January 1, 2022, there were five new Current Procedural Terminology (CPT) codes added to describe remote therapeutic monitoring (RTM). In this article are answers to some of the more common questions private practitioners have been asking about these new CPT codes.

QUESTION

What are the new CPT codes that describe RTM and what is the description of each of the new RTM CPT codes?

ANSWER

Per the American Medical Association CPT 2022, Professional Edition, the new CPT codes and their descriptors are as follows1:

  • 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)
  • 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)
  • 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)
  • 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)
  • 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 [List separately in addition to code for primary procedure])

QUESTION

What is the difference between the new RTM codes and the existing remote physiological monitoring (RPM) codes?

ANSWER

Per the American Medical Association’s CPT Changes 2022: An Insider’s View, on page 178, the main difference is “RPM codes are intended to monitor physiologic parameters such as weight, blood pressure, pulse oximetry, etc. while the RTM codes are intended to monitor services (musculoskeletal system status, respiratory system status, therapy adherence and therapy response) representing the review and monitoring of data related to signs, symptoms, and functions of a therapeutic response.”2

QUESTION

Can physical therapists (PTs), occupational therapists (OTs), and speech-language pathologists (SLPs) bill the RTM codes to Medicare and other insurance carriers and be reimbursed for them?

ANSWER

In the Centers for Medicare and Medicaid Services (CMS) calendar year 2022 final rule for services reimbursed under the Medicare Physician Fee Schedule (MPFS), CMS reversed their previous position that they outlined in the proposed rule and will allow physical therapists, occupational therapists, and speech-language pathologists to bill and be reimbursed for the RTM CPT codes. CMS also clarified that a physical therapist assistant (PTA) under the direct supervision of a physical therapist and an occupational therapy assistant (OTA) under the direct supervision of an occupational therapist could furnish the RTM services.3

QUESTION

What types of practices and organizations will be able to bill the RTM codes?

ANSWER

Per the Centers for Medicare and Medicaid Services (CMS) Transmittal 11118 (which you can view here: https://www.cms.gov/files/document/R11118CP.pdf), CMS states the RTM services can be provided by therapists in private practice or facility-based therapists. Facility-based settings would include Comprehensive Outpatient Rehabilitation Facilities (CORFs), rehabilitation agencies, skilled nursing facilities doing Part B, Home Health Agencies doing Part B in the home and Hospital outpatient therapy departments.4

QUESTION

Will the Annual Therapy Threshold and Multiple Procedure Payment Reduction Policy apply to the RTM codes?

ANSWER

CMS is designating the RTM codes as “sometimes therapy” codes, which means that when provided under an outpatient therapy plan of care, these services will count towards the annual therapy dollar threshold, but the Multiple Procedure Payment Reduction (MPPR) policy will not apply. Since these codes will apply to the annual therapy threshold, they will require the discipline specific modifier be appended to them on the claim form (e.g., GN, GO, GP) when provided under an outpatient therapy plan of care.3

QUESTION

If the RTM codes are provided in whole or in part by a physical therapist assistant (PTA) or an occupational therapy assistant (OTA), will the codes require the CQ/CO modifier and, therefore, 15% reduction apply?

ANSWER

The di minimis standard will apply to CPT codes 98975, 98980, and 98981 if provided in whole or in part by a PTA or an OTA, but the di minimis standard will not apply to CPT codes 98976 and 98977. This means the CQ/CO modifier will be required on CPT codes 98975, 98980, and 98981 if provided in whole or in part by a PTA or an OTA.3

QUESTION

How much will CMS reimburse for each of the new remote therapeutic monitoring CPT codes?

ANSWER

For the payment amounts in the below example, I used Detroit, Michigan, as the payment locality and $34.60 as the 2022 Conversion Factor that is used to determine payment for each CPT code; these payment amounts will increase. The amount below may differ slightly from what is actually paid, and the prices below reflect a non-facility setting.

  • 98975: $19.75
  • 98976: $55.76
  • 98977: $55.76
  • 98980: $50.95
  • 98981: $41.85

To view the payment amount for each of the CPT codes for your payment locality, go to https://www.apta.org/your-practice/payment/medicare-payment/coding-billing/mppr/mppr-calculator.

QUESTION

What CPT codes can be the same day as the RTM codes?

ANSWER

According to the National Correct Coding Initiative (NCCI) edits, Version 28.0, effective with dates of service January 1, 2022–March 31, 2022, CMS will not reimburse for CPT code 97750 (Physical performance test or measurement) on the same date of service a provider also bills either CPT code 98980 or 98981.5</p>

QUESTION

What type of device can I use in order to bill CPT codes 98975, 98976, and/or 98977?

ANSWER

Per the American Medical Association’s CPT Changes 2022: An Insider’s View, on page 177, it states, “To report 98975, 98976, 98977, the device used must be a medical device as defined by the FDA.”6

Per Section 201(h) of the Food, Drug, and Cosmetic Act, a device is:

An instrument, apparatus, implement, machine, contrivance, implant, in vitro reagent, or other similar or related article, including a component part, or accessory which is:

  1. recognized in the official National Formulary, or the United States Pharmacopoeia, or any supplement to them,
  2. intended for use in the diagnosis of disease or other conditions, or in the cure, mitigation, treatment, or prevention of disease, in man or other animals, or
  3. intended to affect the structure or any function of the body of man or other animals, and which does not achieve its primary intended purposes through chemical action within or on the body of man or other animals and which does not achieve its primary intended purposes through chemical action within or on the body of man or other animals and which is not dependent upon being metabolized for the achievement of its primary intended purposes. The term “device” does not include software functions excluded pursuant to section 520(o).7

QUESTION

In order to bill CPT codes 98976 and/or 98977, must I supply the medical device that captures the recordings and/or programmed alert(s) transmission to monitor the respiratory system or musculoskeletal system?

ANSWER

Yes, you must be the one to supply the medical device that captures the recordings and/or programmed alert(s) transmission to monitor the respiratory system or musculoskeletal system. If the patient is using their own FDA medical device or obtains the medical device from another provider, you would not bill CPT code(s) 98976 or 98977.

QUESTION

I see that CPT codes 98976 and 98977 at the end of their description each state “each 30 days.” Must I do the remote therapeutic monitoring for the entire 30 days to bill CPT codes 98976 and/or 98977?

ANSWER

No! Per the American Medical Association’s CPT Changes 2022: An Insider’s View, on page 177, it states “Codes 98975, 98976, 98977 are not reported if monitoring is less than 16 days.”6

QUESTION

I see that CPT code 98980 states “first 20 minutes.” Can I bill this code if I spend less than 20 minutes in a calendar month?

ANSWER

No! Per the American Medical Association’s CPT Changes 2022: An Insider’s View, on page 178, it states “do not report 98980, 98981 for services of less than 20 minutes.”2

QUESTION

I see that CPT code 98981 states “each additional 20 minutes”. Can I bill this code if I spend less than an additional 20 minutes in a calendar month?

ANSWER

No! Per the American Medical Association’s CPT Changes 2022: An Insider’s View, on page 178, it states “do not report 98980, 98981 for services of less than 20 minutes.” This means to bill 1 unit of CPT code 98981 in a calendar month, you would need to spend 40 minutes providing 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. For the first 20 minutes, you would bill one unit of 98980 and then for the next 20 minutes, you would bill for one unit of 98981. To bill two units of 98981 during a calendar month, you would need to spend 60 minutes providing 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.

There is no substantial portion of time with CPT codes 98980 and 98981. You must do the entire 20 minutes.2</p>

QUESTION

Will Medicare Advantage plans and commercial insurance carriers reimburse the RTM codes if provided and billed by physical therapists, occupational therapists, and speech-language pathologists?

ANSWER

That will be insurance carrier and plan specific and you, the provider, would need to check.

QUESTION

Will Medicare Advantage plans and commercial insurance carriers have a patient cost-sharing responsibility on the RTM codes (e.g., co-pay or co-insurance)?

ANSWER

That will be insurance carrier and plan specific and you, the provider, would need to check.

QUESTION

Has the American Physical Therapy Association (APTA) developed any case scenario’s on when to and how to use the RTM codes?

ANSWER

Yes. Go to the following URL link, accessible to APTA members: https://www.apta.org/your-practice/payment/medicare-payment/rtm-codes-practice-advisory. 

As always, this article is not intended to and does not serve as legal advice or as consultative services but is for general information purposes only.


References:

1American Medical Association. CPT 2022 Professional Edition. 842-843.

2American Medical Association. CPT Changes 2022: An Insider’s View. 178.

3Department of Health and Human Services. “Centers for Medicare and Medicaid Services, Medicare Program; CY 2022 Payment Policies under the Physician Fee Schedule and Other Changes to Part B Payment Policies; Medicare Shared Savings Program Requirements; Provider Enrollment Regulation Updates; and Provider and Supplier Prepayment and Post-Payment Medical Review Requirements.” https://www.federalregister.gov/documents/2021/11/19/2021-23972/medicare-program-cy-2022-payment-policies-under-the-physician-fee-schedule-and-other-changes-to-part. Published November 19, 2021.

4DHHS, CMS. “Publication 100-04 – Medicare Claims Processing – Transmittal 11118.” https://www.cms.gov/files/document/R11118CP.pdf. Published November 10, 2021.

5CM Services, National Correct Coding Initiative Edits. “PTP Coding Edits, Version 28.0.” https://www.cms.gov/Medicare/Coding/NationalCorrectCodInitEd/PTP-Coding-Edits. Updated December 16, 2021.

6American Medical Association. CPT Changes 2022: An Insider’s View: 177.

7U.S. Congress. “Federal Food, Drug and Cosmetic Act, Chapter II – Definitions, (h)(1)(A)(B)(C).” Modified July 13, 2021. https://www.govinfo.gov/content/pkg/COMPS-973/pdf/COMPS-973.pdf.

Rick Gawenda, PT

Rick Gawenda, PT, is the founder and president of Gawenda Seminars & Consulting, Inc. He may be reached at info@gawendaseminars.com and on Twitter @gawendaseminars.

Copyright © 2018, Private Practice Section of the American Physical Therapy Association. All Rights Reserved.

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