Understanding Remote Therapeutic Monitoring: Benefits and Billing
What is Remote Therapeutic Monitoring (RTM)?
Remote Therapeutic Monitoring (RTM) services monitor health conditions, including the status of the musculoskeletal system, respiratory system, cognitive behavior therapy, therapy (medication) adherence, and therapy (medication). RTM is intended for the management of patients utilizing medical devices that collect non-physiological data.
Why is RTM important?
By providing care to patients remotely through these digital technologies, patients are more supported, resulting in increased care quality and patient satisfaction. With these codes, providers can now be reimbursed for providing that additional support to Medicare patients, which was not previously possible.
We expect that as medical device technology continues to improve in parallel with our ability to make use of the resulting data, the trend toward utilization of patient data and remote monitoring will continue. By adding these codes, it indicates that CMS also sees that digital care for rehab is important and will continue to expand and that they are invested in that expansion.
How can Actuvi help with RTM?
The Actuvi RTM solution meets the FDA’s definition of a Medical Device that is eligible for billing against CMS’s new RTM codes.
To help our clinicians bill against these codes, Actuvi has built a comprehensive digital platform. Providers can onboard patients and assign them a digital home program that includes education and exercises. Once assigned, providers can track patient utilization of assigned HEP programs, update and modify programs for remote treatment, and facilitate communication between the patient and their care team, all from within the Actuvi RTM solution.
In the Actuvi RTM program, clinicians can track patient device onboarding and the time spent reviewing the resulting data. Actuvi also provides patient data monitoring and maintains all of the required auditable documentation. If you’re interested in using the Actuvi RTM solution at your organization.
Does Actuvi meet the FDA requirements for a medical device as described in the new CPT codes?
Short answer: Yes!
Just like the Remote Patient Monitoring codes (a separate set of CPT codes) the RTM codes require that any device used for monitoring must meet the FDA’s definition of a medical device (as opposed to, for example, a general wellness device).
What are the inpatient applications for RTM?
Inpatient facilities are unable to bill or use RTM because it is a Medicare Part B service. They can help facilitate an engaging digital patient care program by helping the patient download the application to their phone and logging them in before their outpatient evaluation.
Does RTM replace in-person visits?
No, RTM is not intended to replace in-person visits. RTM serves as an adjunct to in-person care, helping you get more information about your patients between visits. You can use this information to better connect with and engage your patients between visits and earn additional revenue, but that should not replace the in-person experience.
Will patients have to pay a co-pay for RTM services? How can I communicate that to patients?
If a patient’s insurance has a patient responsibility (i.e. co-pay or co-insurance, then patients receiving RTM services may need to pay for those services just as they would for any other therapy services they receive, such as manual therapy or ther-ex services. For example, for Medicare, there is a 20% co-pay for all services rendered by the provider, and RTM would fall under this. The patient would be responsible for 20% of the reimbursed amount for the RTM codes.
We recommend communicating that to your patients in the same way you would any other co-payment by explaining the patient's plan of care, stating that it includes RTM services and that depending on what their insurance provider reimburses, they may need to pay a co-payment.
As always, reach out to your billing department and/or your payor contacts for verification.
Billing Questions
Who can bill for RTM?
Providers who are eligible to bill Medicare directly for their services and whose scope of practice includes RTM services are eligible to order and bill for RTM services. This may include:
Physicians
Anesthesiology Assistants
Certified Nurse Midwives
Certified Registered Nurse Anesthetists
Clinical Nurse Specialists,
Clinical Social Workers
Nurse Practitioners
Occupational Therapists in Private Practice*
Physical Therapists in Private Practice*
Physician Assistants
Psychologists
Qualified Audiologists
Speech Language Pathologists in Private Practice*
Registered Dietitians or Nutrition Professionals
In all cases, practitioners must practice in accordance with applicable state law and scope of practice laws.
Not when a patient is inpatient in a hospital or SNF.
What are the new RTM codes and how are they billed?
There are 5 CPT codes for RTM:
Device Set Up (CPT Code 98975)
What is covered: Remote 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.
Clinical example: If you talk with your patient about a home program, get them logged into the app, and provide an overview of how to navigate the app, you’ve met the set-up and education requirements for this code. Once monitoring has occurred for 16 days in a 30-day period, you can be reimbursed for that time.
How it’s used:
· Report this code once per episode of care.
· Only report if monitoring occurs over at least 16 days.
Device Supply (CPT Codes 98976, 98977, and 98978)
What is covered:~ Remote therapeutic monitoring (e.g., respiratory system status, musculoskeletal system status, cognitive behavior therapy, therapy adherence, therapy response), device(s) supply with scheduled (e.g., daily) recording(s) and/or programmed alert(s) transmission, each 30 days.
98976 refers to monitoring of the respiratory system
98977 refers to monitoring of the musculoskeletal system
98978 refers to monitoring of the cognitive behavior therapy
Clinical example: When your patient accesses their program from home, each day they complete exercise activity, respond to surveys, or send messages counts towards the 16 scheduled recordings. Once they’ve had 16 such days within a 30-day period, you can be reimbursed via this code.
How it’s used:
Make sure to use the appropriate code based on the system being monitored
Only report these codes if the patient has had at least 16 scheduled recordings and/or programmed alerts transmitted in a 30-day period.
Remote Treatment (CPT Codes 98980 and 98981)
What is covered: 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.
98980 refers to the first 20 minutes of provider time during the calendar month.
98981 refers to each subsequent 20 minutes of provider time during the calendar month.
Clinical example: When you spend time calling your patient, reviewing patient activity, responding to messages, and updating your patient’s program, it all counts towards 98980 and 98981. Actuvi’s platform will track this time automatically to relieve your staff of manual time tracking.
How it’s used:
98980 should only be billed once each calendar month. 98981 can be billed multiple times for each additional 20 minutes of activity after the first 20 minutes.
One interactive communication needs to occur for each calendar month in which you bill these codes. For example, if you record 40 minutes of activity within a calendar month, you can bill for both codes as long as at least one interactive communication session has occurred.
Healthcare professional time includes time spent reviewing patient activity, responding to messages, and communicating with patients interactively.
How do I know when 16 days of activity have been completed by my patient?
You can use dashboard and billing pages to review activity for all your patients. Organizations have varying interpretations of what a day of monitoring entails as it relates to these CPT Codes.
Based on your organization’s policy, you will use one of the following data points to determine activity data:
Patient Access Days: The total number of days since the patient first logged in (ie. activated) after RTM was enabled for the episode of care.
Patient Activity Days: The total number of days that the patient completed an activity, as defined below, after RTM was enabled for the episode. If a patient completes multiple activities on a single day, that day will only be counted one day.
Patient Activities: logged adherence, messaged clinician, read message, loaded an exercise, completed an assessment, completed connected physiological device reading.
Your organization should determine which approach is right for your organization’s needs. Always refer to your organization’s guidelines when submitting for reimbursement.
How is interactive communication defined?
As it pertains to the RTM CPT codes, interactive communication is defined as any two-way communication. This usually means a phone call or telehealth virtual visit, but can also mean a face-to-face conversation (as long as that conversation time is not being used towards billing other codes). You can log any interactive communication that occurs from the Communication Log on the patient’s profile, making it easy to know when you’ve met this threshold. Actuvi’s platform will also automatically track communication via audio and video calls on the platform and log the communication requirement as completed.
Are there differences in how RTM is handled for facilities and non-facilities?
Facilities and non-facilities should follow the process outlined in the APTA RTM practice advisory. For additional clarifications check with the APTA and your payers.
What payers will reimburse for RTM billing codes?
The landscape of reimbursement for RTM continues to have some variance, but more clarity has come to light as these codes have continued to be used. The American Medical Association has recently published a research brief that details which codes many providers will pay for, including Aetna, Cigna, and many Blue Cross Blue Shield regions. You can download the AMA's research brief by ~[visiting the AMA website](https://www.ama-assn.org/practice-management/digital/ama-future-health-issue-brief-commercial-payer-coverage-digital)~.
As always, we recommend working with your organization to determine the right approach to any billing decisions. Actuvi also provides an initial billing review of your payors and can share in report during the onboarding process.
Are the RTM codes subject to multiple procedure payment reduction (“MPPR”)?
No. CMS designated the RTM codes as “sometimes therapy” codes which means that while they will count towards the annual therapy threshold, MPPR will not apply.
Are the RTM codes subject to the PTA/COTA payment differential?
RTM codes 98975, 98980, and 98981 will be subject to the payment differential (15% reduction) if provided in whole or in part by a PTA/COTA. RTM codes 98976, 98977 and 98978 will not be subject to the payment differential (ie. the de minimis standard).
This payment differential applies if a PTA/COTA conducted more than 10% of the treatment time for a given code. For example, if you are billing for 98980, and 17 minutes were performed by the PT with 3 minutes performed by the PTA, the reimbursement will be subject to the payment differential.
If my patient is not able to record 16 days of monitoring within the same month to bill for 98976/98977/98978, can I still bill for 98980/98981?
Yes, you should be able to bill for 98980/98981 if you meet the time requirement of 20 minutes or more and conduct at least one interactive communication.
Does 98975 require 98977 to be fulfilled to be billed?
Yes
Does 98980 require 98975 or 98976 to be fulfilled to be billed?
Based on our interpretation of the guidance provided by CMS, 98980 is independent of 98975 and 98977. In the ~[2024 Physician Fee Schedule Final rule](https://public-inspection.federalregister.gov/2023-24184.pdf)~, CMS stated "We would like to offer clarification that the 16 day data collection requirement does not apply to CPT codes...98980, and 98981. These CPT codes are treatment management codes that account for time spent in a calendar month and do not require 16 days of data collection in a 30-day period."
Note that this clarification impacts Medicare, but if you're billing other payers, you will need to check with that payer's coverage policies.
As always, defer to your organization’s guidelines for any guidance on RTM billing.
How is billing for RTM impacting the patient's eligibility for in-person visits? Is it counting towards their yearly allowance?
We are hearing that for some commercial insurances if RTM is billed on a separate date of service (DOS), that may count towards a person's visit eligibility. We recommend you reach out to your payor contact for verification and clarification.
When should an organization document or drop the charges for RTM?
Documentation requirements vary based on your state, payor, and EHR, and we recommend you reach out to the payor or their 3rd party intermediary who provides guidance with billing if you have questions. Here are a few things to keep in mind:
If the code is dropped on a different date of service (DOS) than an in-person visit DOS, an additional co-pay may be required from the patient. In some cases, the new DOS may count as an in-person visit, which would count against the patient’s yearly visit allowance for some commercial insurances.
Some insurances allow for the RTM codes to be added to the same DOS as an in-person visit. In this case, a new co-pay would not be required and it should not count against the yearly visit allowance.
As always, contact your organization's billing department and/or your payor contacts for clarification before putting these recommendations into practice.
