In July, the Centers for Medicare and Medicaid Services (CMS) released its proposed Medicare Physician Fee Schedule (MPFS) for Calendar Year 2022, containing new CPT® codes for Remote Therapeutic Monitoring (RTM). If approved, these amendments would have major implications for not just physicians and nurses, but also other healthcare practitioners including physical therapists, occupational therapists, speech language pathologists (SLPs), clinical psychologists, and more.
RTM Codes Can Cover Monitoring of Non-Physiologic Data
RTM would broaden the scope of remote monitoring offerings that healthcare practitioners can provide to patients. While RPM pertains to physiological monitoring, RTM would allow for monitoring of “non-physiologic data”.
Although CMS does not specifically define “non-physiologic data,” it does acknowledge that RTM could be used to monitor health conditions through data related to, for example, musculoskeletal or respiratory system status, as well as therapy (medication) adherence and response.
Self-Reported Data to Be Allowed
Another major difference RTM brings is the ability for patients to self-report data.
Self-reported data would enable inclusion of monitoring non-physiologic metrics such as pain levels and medication adherence, which may or may not typically be captured and transmitted through existing equipment.
As with RPM, RTM data must be transmitted through a “medical device” as defined by the FDA.
Self-reported data could also potentially entail the use of an app or web-based platform that would be classified as Software as a Medical Device (SaMD).
Combined with the data that is automatically captured and transmitted in an RPM system, the self-reported data sent via an RTM program could provide healthcare practitioners with a more holistic view of patient progress. Additionally, it has the potential to boost patient engagement, as they would be participating more interactively with the system.
Wider Practitioner Eligibility and Reimbursement
The proposed RTM rules also open the eligibility pool for reimbursement to a greater number and wider variety of healthcare practitioners.
The proposed rules indicate that nurses and physician therapists could be the primary billers for these codes. This could be beneficial for physical therapists, occupational therapists, SLPs, clinical psychologists, and other practitioners not currently eligible to bill for RPM.
The proposed CPT® codes for RTM closely mirrors those for RPM. There is a code for set-up and education, two device codes, and two services codes. CMS is proposing to pay RTM services codes 989X4 and 989X5 at the same rate as the parallel RPM services CPT® codes 99457 and 99458.
Our partners at Nixon Gwilt Law have published a number of articles containing more detailed information about the proposed RTM rules for 2022.