How CMS is Advancing Remote Patient Monitoring with New CPT Codes in 2022

The Centers for Medicare and Medicaid Services (CMS) released the 2022 Physician Fee Schedule final rule on November 2. The Physician Fee Schedule helps determine payment and reimbursement rates, clarifies evaluation and management policies, makes changes to policies for the 2022 performance year of the Quality Payment Program, and includes other code provisions.

What does the 2022 Physician Fee Schedule say about Remote Physiologic Monitoring (RPM) codes? There are no revisions to the current RPM codes in the 2022 final rule. Instead, the 2022 Physician Fee Schedule expands the practice of RPM into something called Remote Therapeutic Monitoring (RTM).

What is Remote Therapeutic Monitoring?

The new RTM codes expand upon the existing RPM codes, representing one of the latest advancements to modernize reimbursement for digital health. They are meant to help advance virtual care, give healthcare providers more opportunities for reimbursement in RPM programs, and expand the use of digital health tools to provide more comprehensive data to practitioners.

Officially titled “Remote Therapeutic Monitoring/Treatment Management”, these codes are specifically focused on respiratory system status, musculoskeletal system status, therapy adherence, and therapy response. There are five codes in total, and they are all set to go-live starting January 1, 2022.

What are the Remote Therapeutic Monitoring codes?

The RTM family consists of three PE-only codes - 98975, 98976, 98977 - and two codes that include professional work CPT codes - 98980, 98981.

CPT Code 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.

CPT Code 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.

CPT Code 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.

CPT Code 98980

Remote therapeutic monitoring treatment, 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 (base code).

CPT Code 98981

Remote therapeutic monitoring treatment, 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).

Remote Therapeutic Monitoring vs. Remote Physiologic Monitoring: What's the Difference?

While RTM is intended to supplement the existing RPM codes, there are key differences between the two in the nature of data, the method of data collection, and the eligible billing practitioners.

• RTM covers monitoring of self-reported data. Just like RPM monitoring devices, RTM devices must be approved by the U.S. Food and Drug Administration, and those devices can automatically transmit data directly from the device to the practitioner. However, unlike RPM, data collected by the RTM device can include self-reported data.

• RTM covers monitoring of non-physiologic data. RTM codes provide coverage for monitoring certain data points that are outside the scope of RPM, including therapy adherence and therapy response.

• RTM and RPM codes are classified differently. RTM codes are classified as general medicine codes and not Evaluation and Management (E/M) codes. In contrast, RPM is classified as an E/M service.

• RTM is intended to be ordered and billed by a broader range of providers, including therapists. General medicine codes can be ordered and billed by practitioners who are not eligible to bill E/M services. Thus, practitioners like physical therapists, occupational therapists, dietitians, clinical psychologists, and other qualified healthcare professionals can order and bill for RTM without a physician or nurse practitioner (unlike RPM).

• Incident-to billing under general supervision is not allowed for RTM. RPM allows billing practitioners to leverage clinical staff via incident-to billing under general supervision. However, since RTM is a general medicine code, it does not allow the same. This means physicians cannot order and bill for RTM services while having remote-based non-physician practitioners perform the work under general supervision.

• RTM is limited to respiratory and musculoskeletal conditions. The two RTM device supply codes (98976 and 98977) are similar to the RPM device supply code, 99454. However, 98976 and 98977 restricts the clinical or biological systems being monitored to the respiratory system and musculoskeletal system, respectively. In comparison, although the data must be physiological, 99454 does not restrict the clinical or biological systems being monitored.

RPM, RPM, and Digital Care Technologies

Remote monitoring will continue its growth as an area of significant upside potential over the coming years. As we move into the future, more opportunity exists to support patients beyond the four walls of the care setting.

We invite you to learn more about the benefits of RPM, RTM, and digital care technology with Veta Health.