REMOTE THERAPEUTIC MONITORING FOR 2022

Barbara Frances Kho, RN MAN

 CMS PROPOSAL

WHAT ARE THEY PROPOSING?

• CMS published proposed

July 2021
rule for 2022

Septembe • All comments must be submitted to CMS before

r 2021 September 13

December • CMS issues the final rule

2022 effective January 2022
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DIFFERENCE BETWEEN RPM AND RTM

REMOTE PATIENT MONITORING REMOTE THERAPEUTIC MONITORING

TRACKS PHYSIOLOGIC DATA TRACKS SELF REPORTED DATA/NON PHYSIOLOGIC DATA

 HEART RATE
 BLOOD PRESSURE  RESPIRATORY SYSTEM STATUS

 BLOOD SUGAR LEVEL  MUSCULOSKELETAL STATUS

 PAIN LEVELS
 WEIGHT
 THERAPY/MEDICATION ADHERENCE
 OXYGEN
 MEDICATION SIDE EFFECT
 MOOD
 ONLY PROVIDERS/PHYSICIANS CAN BILL FOR RPM

 NURSES, PRACTIONERS AND THERAPIST CAN BILL

FOR RTM

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PROPOSED
CODES

CPT 989X1
CPT 989X2
CPT 989X3
CPT 989X4
CPT 989X5
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 Is used to report the set up and patient
CPT CODE education on RTM and use of device.
989X1 As such, this code is billed once per
patient on the initiation of RTM
services

Average pay rate: $21

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 CPT CODE
Is the monthly code that
989X2
reimburses for the supply of the
device and monitoring of the
patient data, use of equipment
and transmission of data used to
monitor the respiratory system.

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 CPT CODE
Remote therapeutic monitoring;
989X3
devices supply with scheduled
recordings and programmed
alerts transmission to monitor
musculoskeletal system, each
30 days

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  Remote therapeutic monitoring treatment
CPT CODE management services, physician/other
989X4 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
 The first 20 minutes of logged time each
month is billed to this code
 Average pay: $55

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  Remote therapeutic monitoring treatment
management services, physician/other
CPT CODE 989X5
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
 Additional 20 minutes of logged time each
month is billed to this code
 Average pay $44, can be billed twice per
month
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REMOTE THERAPEUTIC MONITORING CODES

 This will require a medical device to access this data, transfer this data
 With this new remote therapeutic codes, you can monitor self reported
data such as pain level, therapy and medication adherence. So, in order to
use these codes you have to have a medical device.
 Suggestions are a software, an app or a web platform classified as
Software as a Medical Device (SaMD) where they can input these data so
it can accurately be billed as such.

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QUESTIONS ON REMOTE THERAPEUTIC MONITORING

 The 2022 proposed Medicare Physician Fee Schedule (MPFS) reflects confusion to among CMS
policy makers as to what types of practitioners are actually allowed to bill for RTM and how they can
go about doing so.
 This confusion must be clearly resolved in the final 2022 MPFS
 The following codes 989x1,989x2.989x3 are direct practice expense so these codes cannot be billed by
physical therapist. This is contrary to what the intent of RTM code was made for that other health care
professionals can bill using these codes.
 Reimbursement for RTM devices are limited to musculoskeletal and respiratory devices as described in
code 989x2 and 989x3. Limiting reimbursement to these specific devices ignores software like SaMD
and other devices that collect important non-physiological data on pain, mood, adherence, etc. So
which part of the code can other non-physiological data can be billed?

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CMS IS SEEKING COMMENTS ON HOW TO REMEDY THE ISSUES
RELATED TO THE RTM CODE CONSTRUCTIONS TO PERMIT SUCH
BILLING TO OTHER HEALTH CARE PROFESSIONALS

CMS IS ALSO SEEKING COMMENTS ON THE TYPES OF DEVICES

THAT MIGHT BE USED TO COLLECT RTM DATA AND
SUGGESTIONS FOR HOW TO CONSTRUCT RTM CODES FOR NON-
PHYSICIAN PRACTIONERS.

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