In 2022, the Centers for Medicare and Medicaid Services (CMS) first allowed rehabilitation providers—occupational therapists, physical therapists, and speech-language pathologists—to bill for RTM (remote therapeutic monitoring). This long-awaited shift unlocked significant advantages, including opportunities for revenue diversification and enhanced patient outcomes, to name a few.
Recently, the new 2024 CMS Proposed Rule has offered up some changes affecting RTM in rehabilitation therapy. Spoiler alert: Some of these changes are good news for therapy providers!
But what do you need to know to navigate these changes? How can you manage your RTM billing to secure reimbursements more efficiently and enjoy the cost-saving benefits of RTM?
Keep reading to find out!
Frequently Asked Questions About Remote Therapeutic Monitoring
Here are some need-to-know RTM FAQs to help you understand and make the most of this therapeutic approach. For an at-a-glance reference, check out our RTM infographic!
Key Definitions in Remote Care
What Is Remote Therapeutic Monitoring?
Remote therapeutic monitoring allows providers to monitor the status of patients' self-reported health and treatment outcomes between visits. Specifically, RTM collects and analyzes non-physiologic data—such as pain levels and therapy adherence—to provide insights into the progress and efficacy of patient care.
What Is Remote Patient Monitoring?
Remote patient monitoring utilizes digital technologies to electronically collect and transmit health data such as vital signs, weight, blood pressure and even range of motion. These monitoring programs give providers easy access to a hub of patient physiologic data. Unlike RTM, physiologic data collected for RPM cannot be self-reported.
What Are the Similarities Between RPM and RTM?
There are a few fundamental similarities between RTM and RPM, which makes it easy to confuse the two.
- On the broadest level, RPM and RTM both fall under the umbrella of telehealth.
- Both allow providers to bill for asynchronous care: when information transfer and review occur at different times. This creates convenience for both patients and providers, and can eliminate certain barriers to care. More on this later!
- RPM and RTM can have a huge impact on practice revenue. CPT codes for these services allow providers to document and collect payment for value provided outside of real-time appointments.
- Both RPM and RTM require the use of a medical device as defined by the FDA guidelines in section 201(h) of the Federal Food, Drive, and Cosmetic Act (FFDCA). [See: What Devices Are Used for Remote Therapeutic Monitoring?]
Benefits of RTM in Rehab Therapy
What Are the Clinical Benefits of Remote Therapeutic Monitoring?
Benefits for Providers
Using RTM data, providers can make data-driven decisions about continued and future treatment.
Benefits for Patients
RTM can help patients become more aware of their health and motivate stronger treatment adherence.
What's the Importance of RTM for Rehabilitation Therapy?
With RTM, rehabilitation therapy patients can self-report critical information on pain severity or duration, medication or therapy adherence, or other factors to you at set intervals. That way, you collect better and more timely patient data between therapy sessions. You can use this information to assess the effectiveness of current treatment strategies and adjust if necessary, ultimately leading to better patient outcomes.
Billing for Remote Therapeutic Monitoring
Who Can Bill for Remote Therapeutic Monitoring?
RTM codes are classified as general medicine codes. That means RTM services can be billed by physicians and eligible healthcare professionals, including practitioners such as physical therapists, speech-language pathologists, occupational therapists, clinical social workers, and other qualified professionals.
The definition of a qualified healthcare professional who can bill for RTM is:
... An individual who is qualified by education, training, licensure/regulation (when applicable) and facility privileging (when applicable) who performs a professional service within his/her scope of practice and independently reports that professional service.
This is a departure from RPM codes, which are only available for providers who can bill evaluation and management (E/M) codes.
What Are the Remote Therapeutic Monitoring codes?
There are six CPT codes used to bill for RTM. Five of these can be used by rehabilitation therapists who treat respiratory or musculoskeletal conditions, and the sixth is a code for behavioral health providers who use RTM to support cognitive behavioral therapy treatment.
CPT Code #98975
This code is used to bill for initial set up and patient education regarding RTM equipment. The industry average reimbursement is about $19.
CPT Code #98976
This code is used to bill for RTM services that monitor the respiratory system status and treatment progress over the course of 30 days. The industry average reimbursement is about $55.
CPT Code #98977
This code is used to bill for RTM services that monitor the musculoskeletal system status and treatment progress over the course of 30 days. The industry average reimbursement is about $55.
CPT Code #98978
As of 2023, this code is used to bill for supplying one or more devices that support RTM for cognitive behavioral therapy, reported once per 30 days.
CPT Code #98980
This code is used to bill for the first 20 minutes of interactive communication with a patient or caregiver, required as part of RTM treatment within a calendar month. The industry average reimbursement is $50.
CPT Code #98981
This code is used to bill for each additional 20 minutes of interactive communication with a patient or caregiver, required as part of RTM treatment within a calendar month. The industry average reimbursement is $40.
The Centers for Medicare and Medicaid Services (CMS) maintains a list of CPT codes and healthcare common procedure coding system (HCPCS) codes, updated annually.
Is RTM Limited to Respiratory and Musculoskeletal Conditions?
Previously, the billing codes for RTM exclusively focused on respiratory and musculoskeletal conditions. However, the most recent CMS Final Rule broadened the use of RTM to cover cognitive behavioral therapy (CBT), as well.
More Important Details
What Devices Are Used for Remote Therapeutic Monitoring?
Devices used for RTM must fit within the Food and Drug Administration (FDA) definition of a medical device under section 201(h) of the Food, Drug & Cosmetic Act.
... An instrument, apparatus, implement, machine, contrivance…or other similar or related article, including a component part, or accessory which is…intended for use in the diagnosis of disease or other conditions, or in the cure, mitigation, treatment, or prevention of disease [or] injury.
Medical devices must also meet FDA product classification parameters. Searching the FDA product classification database for existing products that match a device’s intended use or design can help you determine if a device qualifies as a medical device. Notably, mobile apps—often invaluable for RTM data collection—can meet the FDA’s definition of a medical device.
How Do You Educate Patients About RTM?
Some patients may immediately see the potential benefits of RTM, while others will need some coaching. Remember, the value of RTM relies on patients to participate and self-report their therapeutic data.
Patient education may be necessary to support adoption of RTM devices or programs. Consider establishing scripts or guidelines for how to discuss RTM with the patients at your practice, both at the start and throughout the treatment journey.
RTM and the Calendar Year (CY) 2024 Medicare Physician Fee Schedule
Looking ahead, the CMS Proposed Rule for 2024 has put forward changes that affect healthcare organizations using RTM, specifically:
- Supervision of physical therapy and occupational therapy assistants. To date, CMS has required that occupational and physical therapists directly supervise physical therapy assistants (PTAs) and occupational therapy assistants (PTAs) in private practice. With the new Proposed Rule, CMS plans to allow for RTM-specific general supervision of therapy assistants. This proposed change will allow OT and PT private practices to bill for RTM services performed by OTAs and PTAs.
- Expansion to rural and federally qualified health centers. The new Proposed Rule proposes to include RTM into a general care management services code (G0511) for Rural Health Centers (RHC) and Federally Qualified Health Centers (FQHC). With this change, underserved populations in rural and remote areas can have more access to RTM services, leading to more opportunities for early intervention treatments and improved health outcomes.
- Clarification of RTM use during global surgery periods. In the new Proposed Rule, CMS proposes that practitioners may receive payment for RTM or RPM services (but not both concurrently), separate from any global service payments for services.
- Reinstatement of minimum data collection requirements. During the COVID-19 public health emergency (PHE), CMS altered its billing policy for remote data collection. With the end of the PHE, CMS is reinstating its requirement for remote data collection at least 16 days in a 30-day period.
Putting RTM to Work for Your Practice
With RTM, you can stay connected to patients and track high-value data to shape their treatment plans between in-office visits. This is a huge win for both you and your patients.
Do you have the right systems to help your practice succeed? Raintree’s scalable platform for rehabilitation practice management and electronic health records (EHR) system includes everything you need to streamline routine tasks, elevate your efficiency, and drive revenue.
