Urgent Action Needed: Tell CMS to Support Remote Therapeutic Monitoring

In July 2022, the Centers for Medicare and Medicaid Services (CMS) released the proposed rule for calendar year 2023 for services reimbursed under the Medicare Physician Fee Schedule (MPFS). This proposed rule includes changes that could cut reimbursements and impact the future of remote therapeutic monitoring (RTM) for physical and occupational therapists.

Comments received online are due on September 6, 2022 by 11:59pm EDT (5pm EDT for comments received by mail), and we are urging physical and occupational therapists to make their voice heard by taking five minutes to send comments to CMS on the proposed RTM changes for calendar year 2023. To help, we’ve provided a response letter template that recommends the following:

  • Urges CMS to restore the practice expense for the proposed GRTM 3 and GRTM 4 by including the clinical staff inputs for non-facility payments.
  • Recommends CMS to allow virtual direct supervision of physical therapy assistants and occupational therapy assistants for the purpose of improving patient access to RTM services by facilitating a centralized model of care.
  • Recommends permitting providers to bill for proposed RTM treatment codes (HCPCS codes GRTM 2, 3 and 4) without the requirement to first bill codes 98975 through 98977.  
  • Recommends CMS to delete the following parentheticals that appear in Table 28:
    • (CPT codes 98975 and 98976 or 98977 must be billed prior to reporting GRTM 1, GRTM 2, GRTM 3 and GRTM 4) 
    • (At least 16 days of data must be reported).

To submit your comment, simply:

  1. Download our response letter template
  2. Add, revise, and/or delete comments and save changes
  3. Add your name and professional designation to the letter
  4. Visit the official comment page and click ‘Submit a Formal Comment’
  5. Upload doc, or copy and paste contents of letter
  6. Fill in all required fields and submit comment