The Centers for Medicare and Medicaid Services (CMS) published its new proposed Medicare Physician Fee Schedule for Calendar Year 2022 on July 13th to address “Remote Therapeutic Monitoring.” It covers five new CPT codes for “non-physiologic” patient data such musculoskeletal system status, respiratory system status, therapy (medication) adherence, and therapy (medication) response, as well as pain.
The recent RTM proposal acknowledges the value of remote monitoring and encourages the adoption of digital health solutions to provide practitioners with a more complete picture of their patients’ health problems.
Definition of Remote Therapeutic Monitoring
RTM is a set of codes established by the American Medical Association (AMA) in October 2020 and valued by the RVS Update Committee in January 2021. RTM services are similar in structure and nature to RPM service— with a code for RTM equipment set-up and teaching, two device codes, and two services codes. CMS has recommended the following CPT codes for RTM coverage, based on guidelines established by the AMA’s Digital Medicine Payment Advisory Group over the past year:
- 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; and
- CPT code 989X5: Remote therapeutic monitoring treatment management services, physician/other qualified healthcare 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 the RPM and RTM codes have some similarities, CMS noted certain important variations in the nature of the data collected, how the data is collected, and which clinicians are authorized to bill for RTM services.
The first thing to consider is that providers who are unable to bill for RPM may be able to bill for RTM. Medicare points out in the proposed rule that the way the AMA defined the RTM codes as non-evaluation and management (E/M) codes does not allow Medicare to identify them as general supervision care management codes. They are gathering for comments on how to solve these inconsistencies.
The second point to consider is the nature of the data collected— whether it is therapeutic for RTM or physiological for RPM. In comparison to RPM codes, RTM codes promise greater use cases and applications in patient care.
The third point to consider is how the data is collected using a device. RTM and RPM both necessitate the use of a medical device. However, RTM data can be self-reported by the patient as well as digitally supplied via the device, according to CMS’ statement. RPM, on the other hand, necessitates that the device digitally (that is, automatically) capture and upload patient physiologic data (i.e., data cannot be patient self-recorded, self-reported, or entered manually into the device).
Takeaway
The CMS proposed rule improves clinicians’ ability to use remote monitoring technologies to improve patient care, but technical issues and inconsistencies must yet be worked out. DrKumo will continue to keep an eye on CMS for any regulation changes or guidelines that may influence or increase RPM and RTM opportunities.
Click here to view the full proposed rule for the 2022 Medicare Physician Fee Schedule.
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