Remote Patient Monitoring (RPM) and Remote Therapeutic Monitoring (RTM)

Back in December of 2020, the CMS adopted the 2021 Physician Fee Schedule Final Rule policies for proposed RTM coding additions that could allow non-physicians, such as physical therapists and nurses, to bill separately from physicians, as well as expand coverage to include certain therapies and procedures now in question. The rule’s intent is to further clarify the CMS’ position on interpreting monitoring requirements, building on earlier RPM guidance from healthcare professionals and telehealth and related organizations. While the September 13. 2021 deadline for submitting comments has just passed, the situation is worth watching for practices utilizing telehealth as well as medical billing companies.

The issues at the center of all this:

• How CMS defines remote patient monitoring
• How it intends to reimburse health care providers for the collection of data and related activities in caring for patients in their homes. 

Several professional groups, including the American Telemedicine Association (ATA), have leveled criticism against the CMS for not going far enough with new codes as well as falling short of setting sufficient definitions of patient monitoring and allowing separate billing for services by the above and other groups of non-physician health care professionals.

A handful of new RTM codes aren’t enough

The ATA and other groups, especially physical therapists, are insisting that while the codes (below) are an improvement, they don’t go far enough. CMS had developed a few codes for what was termed “remote physiological monitoring” in 2019 which were kept separate from other forms of its telehealth coverage, with some providers given leeway to begin RPM programs using connected healthcare technology to monitor homebound patients.

The new CPT codes below are included in a category in the 2022 Physician Fee Schedule proposal for addressing what CMS terms “remote therapeutic monitoring.”

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 the 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 alerts transmission to monitor respiratory system, every 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 alerts transmission to monitor musculoskeletal system, every 30 days.

CPT code 989X4: 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, 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. (To be listed separately in addition to code for primary procedure.)

According to attorney Carrie Nixon, a managing partner of Nixon Gwilt Law, part of the Telemedicine & Digital Health Industry Team, while a number of questions remain, some of its positive results will be reimbursing RTM service codes 989X4 and 989X5 at the same rates as it now reimburses for codes 99457 and 99458.

On the other hand, Nixon believes that the RTM and RPM codes could be aligned better, allowing more providers to utilize the coverage and bill for more collected data. She also reports that the CMS needs to clarify that the proposed (RTM) codes disallow clinical staff time’s incident-to-billing under the general supervision of physicians, physician assistants, nurse practitioners, or other qualified health care professionals (QHCPs) ordering RTM services.

Short-term Temporary Recommendations

Nixon recommended creating a set of a temporary set of codes for Medicine HCPS-G codes for RTM and classifying them as care management services subject to general supervision when ordered by a physician or non-physician provider (NPP).

Additionally, she recommends developing a temporary Medicine HCPS-G code for supplying system-agnostic RTM devices. This would expand proposed rules that would limit coverage to musculoskeletal and respiratory devices, excluding technologies treating adherence to medication, pain, mood, and therapy responses.

She also asks CMS to cover RTM services at the same rates as with RPM services.

Nixon believes that CMS needs to create codes in the Final Rule that are aligned with RPM allowing billing practitioners to utilize clinical staff under general supervision to avoid excluding “valuable use” cases for RTM.

The ATA also agrees with Nixon that a temporary set of G codes needs to be created, and criticized the shortfall of integration between RTM and RPM codes. In its comments, they stated that “these (G-codes) will permit incident-to-billing and are necessary to ensure that clinical staff and auxiliary personnel are able to assist in providing RTM services under the general supervision of a billing provider as correctly questioned by the CMS.”

The ATA also stated that CMS missed an opportunity to expand the adoption of RPM codes by not updating its proposed RPM codes in the proposed 2022 PFS.

They urged CMS to make specific changes to ensure availability and use of Medicare-based RPM services, and that allowing for RPM-treatment assessment services would open up permanent billing to non-physician providers, including but not limited to  PTs and others within their scope of practice and benefit categories.  

If the above Final Rule proposals seem confusing, they are and are being closely followed by telehealth providers, as to whether Medicare chooses to amend its proposals will affect planning future connected health care strategies.

In the meantime, your billing and backend departments can count on M-Scribe to professionally and accurately handle all your claims from submission to the right payers in a timely manner, and beyond throughout your revenue cycle. Since 2002 M-Scribe has been helping practices of all sizes and specialties with all phases of claims management and RCM goals and needs. Contact M-Scribe at 770-666-0470 or email us for a confidential assessment of how we can work with you to help you take your practice to the next level.

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