The proposed rule, issued July 13, greatly expanded what was known and understood about RTM but still left many questions unanswered.
Within the nearly 1,750 pages of the 2022 Medicare Physician Fee Schedule proposed rule were many significant policies that, if approved, could greatly affect practices. One particular subject that has largely flown under the radar concerns remote therapeutic monitoring (RTM). This emerging concept should be of interest to organizations with current or future plans to implement telehealth and/or remote patient monitoring (RPM) programs.
The proposed rule, issued July 13, greatly expanded what was known and understood about RTM but still left many questions unanswered. We hope and expect these questions will be answered in the coming months as RTM transitions from an undefined service to one that practices may want to offer patients.
To help you get up to speed on RTM, here are eight things to know.
The CPT Editorial Panel introduced the concept of RTM about two years ago. This was accompanied by a series of five treatment management service CPT codes but few details about what these codes covered. The target effective date for RTM and its codes was announced as Jan. 1, 2022.
“Remote therapeutic monitoring” is not a new way of saying “remote patient monitoring”. Rather, RTM CPT codes (described in detail below) nearly mirror the RPM CPT codes with one major difference: Generally speaking, RTM is designed for the management of patients using medicals devices that collect non-physiological data.
While non-physiologic data has yet to be fully defined by CMS, the proposed rule notes that RTM would be used to monitor a range of health conditions and patients that stand to benefit from remote monitoring outside of the traditional confines of tracking vitals data. Examples of potential non-physiologic data given by CMS include musculoskeletal system status, respiratory system status, therapy/medication adherence, and therapy/medication response.
Which brings us to one of the most significant things to know…
The new proposed codes and coverage are welcomed developments among care providers and their patients as they would allow providers to address noteworthy gaps that exist in the current coverage and delivery of RPM. The addition of coverage for RTM services would help patients experience more consistency and quality along the continuum of care, especially in the realm of chronic disease monitoring.
The proposed rule provides some clarification on how CMS expects RTM and RPM to differ. To summarize the three notable differences:
Here's a quick illustration of how RTM might function. An older patient with multiple chronic conditions is provided a "smart" pill bottle designed to remind the patient when to take their medications. The bottle includes technology that informs the patient's primary care provider whether medications were taken at their appropriate time. The provider can monitor this non-physiologic medication adherence data, or data that is self-reported by the patient, to assess the effectiveness of the smart pill bottle in helping the patient maintain adherence. If the patient is struggling, the provider can explore other solutions to help improve adherence to the medication regimen. Since the pill bottle is not collecting physiological vital signs, it cannot be billed under RPM, but may be billable under RTM.
CMS rarely adopts coverage for new CPT services quickly. However, the proposed rule seems to indicate that coverage for RTM will happen soon, with Jan. 1, 2022, remaining the targeted effective date.
Prior to the proposed rule, we did not have definitions for the five RTM codes. The CPT Editorial Panel had only provided the codes and they each included a placeholder. We now have definitions for each of the codes, but the placeholders remain for the time being.
The RTM codes are currently described as follows:
CPT 989X1, 989X2 and 989X3 are considered practice expense-only codes (i.e., the provision of the service by staff is included in the CPT code's reimbursement; no physician time or work is built into these codes). CPT 989X4 and 989X5 are professional work codes.
The proposed rule document sees CMS recommending several rules concerning RTM and seeking comments to help guide the regulation and 2022 requirements for the service. The proposed rules largely speak to payment for the codes and how they crosswalk to their "mirrored" RPM CPT codes. The comments CMS is seeking concern the typical devices that might be used to collect the data described in the RTM codes and suggestions for how to change the RTM code construction so non-physician providers and practitioners, such as physical therapists, can bill the RTM codes.
Despite all the information shared above, the requirements concerning RTM are vague. The Jan. 1, 2022, effective date for RTM looms, which is why we expect more details and clarification leading up to and in the 2022 Medicare Physician Fee Schedule final rule. Among the areas where clarification is needed include who can bill for RTM, what clinical use cases will be eligible for RTM reimbursement and if RTM be considered an "incident to" furnishable service.
Feedback on the 2022 Medicare Physician Fee Schedule proposed rule must be submitted by 5:00 p.m. ET on Sept. 13, 2021.
About the Author
Daniel Tashnek is the co-founder of Prevounce Health, a healthcare software company that simplifies the provision of preventive medical services, chronic care management and remote patient management. Daniel is also a practicing healthcare attorney specializing in regulatory compliance, reimbursement, scope of practice, and patient care issues.