The new CPT codes released by CMS in 2022 for remote therapeutic monitoring (RTM) have opened up an exciting opportunity for many outpatient rehab providers, allowing them to bill for the remote management of their patients that many have already been performing—but there’s also a learning curve involved.
In our three-part RTM FAQ series, we answer some of your most pressing questions from our recent webinar Remote Therapeutic Monitoring Strategies: 2023 Physicians Fee Schedule & Lessons Learned.
Can a provider set up RTM during in-person treatment time, (either the evaluation or the follow-up)? Is the documentation then performed separately?
Yes—in fact, we recommend that you perform setup during the evaluation or an in-person visit. You’ll need to document what you did and to whom you provided the education and assistance during setup (i.e., the patient, a caregiver, or a family member).
What is the frequency with which therapists need to check on patient adherence to exercises?
There’s no specific frequency requirement by CMS, so that should be determined by the provider or organization. We are seeing that when a clinician engages with the data reported by the patient more frequently and incorporates that into the discussions with the patient, more accountability is created, resulting in patients being more engaged and compliant with their remote programs.
Can a non-licensed provider administer the phone check-in or chat with the patient during their RTM period?
Under an episode of care managed by a PT or OT, all billable interactions need to be performed by a licensed clinician such as a PTA or an OTA. However, if the episode of care is managed by an MD, general supervision of staff is eligible, so a phone check-in could be performed by a non-licensed provider.
Can a physical therapist who is licensed in one state but living in another state administer RTM in the other state?
No, PTs and PTAs need to be licensed in the state where the patient is located.
Can athletic trainers (ATCs) perform RTM?
ATCs can only do so under the supervision of an MD, not a PT or an OT.
Are you recommending separate plans of care for RTM and in-clinic care, or can these be combined with notes kept separate?
RTM and in-clinic care plans should be combined into a single plan of care.
Will RTM notes count against allotted visits for plans that limit the number of visits?
Medicare doesn’t have an allotted visit amount, but rather a dollar threshold. Therefore, services being provided don’t necessarily count against visits. For commercial insurance plans, we advise you to speak to your insurance contact as it could be considered a new date of service/visit if billed on a separate day.
Can I use RTM after discharge?
No, once a patient is discharged from an episode of care they are NOT eligible to be billed for RTM.
Coding and Billing
Can more than one therapist use the codes for the same patient?
RTM can only be billed once per patient per month, so the first clinician to bill for that code will get reimbursed. For example, an OT and a PT can’t both be reimbursed for the same patient session, but they can still co-manage the session.
Can we use RTM codes to bill for physical therapists providing cognitive behavioral therapy?
Yes, you can in 2023. As of 2023, CMS has released CPT code 98978, which is used to reimburse providers who are using RTM to provide cognitive behavioral therapy.
I’m confused about how the 16-days requirement works. Can you provide clarification?
Here are some of the most important points to keep in mind regarding the 16-days requirement:
- Code 98975 requires 16 days of monitoring, and codes 98976 and 98977 require 16 days of scheduled recordings.
- Organizations have interpreted “monitoring” and “scheduled recordings” in various ways. The MedBridge RTM solution provides three data points you can refer to, which are listed below. Your organization can determine which data point is right for you.
- Days Since First RTM Login: The total number of days since the patient first logged in after RTM was enabled for the episode of care.
- Patient Login Days: The total number of days where a patient login occurred after RTM was enabled for the episode. If a patient logs in multiple times on a single day, that day will only be counted one time.
- Patient Activity Days: The total number of days that the patient completed an activity after RTM was enabled for the episode. If a patient completes multiple activities on a single day, that day will only be counted as one day.
- You’re eligible to bill for 98975 with proper documentation and plan of care once the patient has been onboarded, activated (logged in the system at least once), and 16 days of monitoring have occurred within a 30-day window.
- You’re eligible to bill for 98976 or 98977 after patients have recorded 16 days of data transmission within a 30-day window.
- You can bill for the monitoring codes 98980 and 98981 even if 98977 milestones have not been met; however, it is recommended that you bill at least 98975 prior to any billing of 98980 and 98981.
How can MedBridge help with RTM?
The MedBridge Remote Therapeutic Monitoring Solution includes our Home Exercise Program (HEP) Builder, Patient Mobile App, and Patient Portal, and meets the FDA’s definition of a Medical Device that is eligible for billing against CMS’s new RTM codes.
Our comprehensive digital platform allows providers to onboard patients and assign them a digital home exercise program (HEP) that includes evidence-based education and exercises. Once HEP programs are assigned, providers can track patient engagement with the HEP, monitor patient data, update and modify programs for remote treatment, and facilitate communication between the patient and their care team, all from within the MedBridge RTM solution. MedBridge also provides patient data monitoring and maintains all of the required auditable documentation.