Remote therapeutic monitoring

Remote therapeutic monitoring occurs when physical therapists remotely manage their clients for respiratory and musculoskeletal conditions using software or medical devices that collect non-physiological data. Remote therapeutic monitoring’s recent addition to reimbursement for 2022 CMS represents a major acknowledgement in terms of expansion of remote care.

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As technological applications for healthcare continue to expand, the landscape of physical therapy is presented with opportunities to evolve. In 2020 we saw the expansion of telehealth services across many areas of healthcare from physical therapy to primary care services. This allowed for the provision of services remotely, thus limiting contact between providers and their patients during the height of the COVID-19 pandemic.

While this new method of providing care may have been a necessity at the time, many healthcare providers and patients greatly appreciated the convenience of this option and hope to see telehealth options continue to be available. Additionally, we are seeing the development of remote devices that allow for data collection and monitoring of patient presentation and performance between therapy sessions which can inform our treatment decisions.

Insurance companies act as gatekeepers to healthcare services of all kinds. They often control the “who, what, when and where” aspect of healthcare which can be broad or very narrow depending on the insurance plan and its benefits. This means that in order for telehealth and remote healthcare options to maintain viability, there needs to be a way to submit claims for these services with codes that are recognized and reimbursable by payer sources.

What is remote therapeutic monitoring?

In 2021, the Center for Medicare and Medicaid services (CMS) launched the 2022 Medicare Fee Schedule which included 5 new CPT codes for remote therapeutic monitoring (RTM) that can be billed by physical therapists under Medicare and commercial insurance plans as of January 1, 2022, though it is always a good idea to check with specific commercial plans about their coverage.

These remote therapeutic monitoring codes can expand our ability as therapists to provide patient-centered and individualized care through the collection of certain types of data while the patient is at home. This makes these codes ideal for use by therapists practicing in the outpatient or home health setting but not in the inpatient rehab or SNF setting. These also have the potential to increase reimbursement for physical therapists.

What is the purpose of remote therapeutic monitoring CPT codes?

Remote therapeutic monitoring codes specifically refer to the management of medical devices that collect non physiological patient data including things such as therapy/medication adherence or response and pain levels. This differs from remote patient monitoring (RPM) codes which cover devices that gather physiologic data such as heart rate, blood glucose, etc. Three of the codes reflect remote therapeutic monitoring services while two of them reflect Remote therapeutic monitoring treatment and management. It is important to understand the specific definitions and usage principles for each code.

These codes were created to monitor health conditions including those affecting the musculoskeletal system and respiratory status, to monitor adherence to therapy recommendations and response to therapeutic interventions.

5 new remote therapeutic monitoring codes CPT codes

CPT Code 98975: Remote therapeutic monitoring (e.g., respiratory system status, musculoskeletal system status, therapy adherence, therapy response); initial set-up and patient educationon use of equipment.

• How to use this code: Submit this code to account for time spent setting up and educating a patient/caregiver about a remote monitoring device that will monitor the musculoskeletal or respiratory system, adherence or response to therapy.  
• Document: The specific device and any set-up required, what education you provided, how long you spent on this activity and the patient/caregiver level of understanding.

CPT Code 98976: Remote therapeutic monitoring device(s) supplied with scheduled (e.g., daily) recording(s) and/or programmed alert(s) transmission to monitor respiratory system, each 30 days.

• How to use: Submit this code no more than once in a 30-day period and only if monitoring occurred over a period of at least 16 days, to account for time spent monitoring daily recordings or alerts related to the respiratory system.
• Document: The specific device and its cost and what the device is monitoring.

CPT Code 98977: Remote therapeutic monitoring device(s) supplied with scheduled (e.g., daily) recording(s) and/or programmed alert(s) transmission to monitor musculoskeletal system, each 30 days.

• How to use: Submit this code no more than once in a 30 day period and only if monitoring occurred over a period of at least 16 days, to account for time spent monitoring daily recordings or alerts related to the musculoskeletal system
• Document: The specific device and its cost and what the device is monitoring.

CPT Code 98980: Remote therapeutic monitoring treatment management, 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.

• How to use: Submit this code no more than once in a calendar month to account for the first 20 minutes of time spent with the patient/caregiver discussing the results of the data collected through remote monitoring; discussing how to integrate this data into the provision of a care and treatment plan; discussing how this data informs patient-centered goals and answering questions and providing feedback to patients/caregivers.
• Document: The time spent on this discussion, the results of the data collected and how it informs your goals and treatment plan as well as level of patient/caregiver understanding. 

CPT Code 98981: Remote therapeutic monitoring treatment management, physician/other qualified health care professional time in a calendar month; each additional 20 minutes.

• How to use: this code can only be used if A) you have already billed 98980 and B) you have provided an additional 20 minutes (or 40 or 60 minutes, etc.)  of education as outlined by code 98980. You cannot bill this code for time increments less than 20 minutes. 
• Document: The time spent on this discussion. Be sure the time you document is at least an additional 20 minutes (ie. minimum of 40 total minutes of education) if you are going to bill this code.

What else should I know about remote therapeutic monitoring CPT codes?

The CMS 2022 Code List and Dispositions document outlines more specific information about the use of these codes:

• RTM codes can be used by providers other than therapists (physicians, nurse practitioners, physician assistants, psychologists, social workers, etc), but if the monitoring device is specific to physical therapy services “such as the ARIA supply device in CPT code 98977 that includes therapeutic exercises, [it] must also be furnished under a therapy plan of care when provided by physicians and NPPs.”

• As is the case with any service, “although these services are furnished virtually or remotely, they must be reasonable and necessary and documented in the medical record.” They should not be reported by the therapist if “it is not appropriate to bill the service under a therapy plan of care, and they are billed by practitioners who are not therapists, such as physicians, clinical nurse specialists, nurse practitioners, physician assistants, psychologists, social workers, etc., who may also be able to report them.”

• “Services are designated as “sometimes therapy” but, are “always therapy” services when furnished by a therapist and in these situations require the use of a therapy modifier GP, GO or GN, in order to indicate the service is furnished under a physical therapy (PT), occupational therapy (OT), or speech-language pathology (SLP) plan of care, respectively.

• While code 98976 is specific to devices monitoring the respiratory system and 98977 is specific to devices monitoring the musculoskeletal system, the other 3 codes(98975, 98980 and 98981) are not specific to any body system, condition or response. 98975 can be reported in reference to the set-up and education in the use of any remote monitoring medical device as defined by the FDA. The other two codes 98980 and 98981 can be reported for the monitoring of any system or therapeutic response.

• When furnished by a PTA, codes 98976 and 98977, are not subject to the payment adjustment, however code 98975 which represents the initial set-up and education on the device, is subject to the PTA payment adjustment.