The CMS has proposed a new category of digital health services—Remote Therapeutic Monitoring (RTM)—to complement the existing suite of Remote Physiological Monitoring (RPM) codes covered under Medicare. These codes are planned to start in January 2022. The structure and nature of RTM services resemble RPM services.
Table of Contents
ToggleRemote 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.
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 alert(s) transmission to monitor respiratory system, each 30 days.
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 alert(s) transmission to monitor musculoskeletal system, every 30 days.
Remote therapeutic monitoring treatment management services, 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.
Remote therapeutic monitoring treatment management services, 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; each additional 20 minutes.
While there are similarities between the RPM and RTM codes, CMS identified some key differences between the two.
RTM codes monitor health conditions including, but not limited to, musculoskeletal system status, respiratory system status, therapy adherence, and therapy response, and as such, allow non-physiologic data to be collected.
RPM CPT Code 99454 does not restrict the clinical or biological systems being monitored, although the data must be physiological. In contrast, RTM CPT Code 989X2 is only for transmissions to monitor the respiratory system, whereas 989X3 is only for transmissions to monitor the musculoskeletal system. The current RTM device supply codes do not target other systems (e.g., neurological, vascular, endocrine, digestive, etc.).
RTM data can be self-reported by the patient, as well as digitally uploaded via the device. In contrast, RPM requires the device to digitally (that is, automatically) record and upload patient physiologic data, i.e., data cannot be patient self-recorded, self-reported, or entered manually into the device).
The primary billers of RTM are intended to be Nurses and Physical Therapists. The idea is that the new RTM codes would allow practitioners who cannot bill RPM codes to furnish and bill for services that look like those of RPM.
HealthArc has been an industry leader in remote patient monitoring for some time, and the interdisciplinary approach, flexible interface, and seamless interoperability can easily be scaled for Remote Therapeutic Monitoring.
The CMS proposed rules regarding RTM promote clinicians to use remote monitoring technologies to improve the patient care experience, but the technical details still need to be ironed out. We will continue to monitor CMS for any rule changes or guidance that affect or improve both RPM & RTM opportunities.
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