Remote Therapeutic Monitoring: Frequently Asked Questions (FAQ)

The new RTM CPT codes have opened up new possibilities for many providers. And alongside those possibilities, there are many questions. We've collected some of the questions we've most frequently received related to RTM to help you navigate these new billing codes and workstreams.

1. General Questions
2. Billing Questions

General Questions

What is Remote Therapeutic Monitoring (“RTM”)?

Remote Therapeutic Monitoring (RTM) services monitor health conditions, including the status of the musculoskeletal system, respiratory system, therapy (medication) adherence, and therapy (medication). RTM is intended for the management of patients utilizing medical devices that collect non-physiological data.

Over the last year, a new set of Billing Codes have been implemented and are in the process of being refined by the Centers for Medicare & Medicaid Services (“CMS”). These codes are targeted at providing reimbursement for clinicians spending time in the provision of medical devices that can track patient information over time, and the review of the resulting information.

Why is RTM important?

By providing care to patients remote through these digital technologies, patients are more supported, resulting in increased care quality and patient satisfaction. And 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 towards utilization of patient data and remote monitoring will continue. And 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 MedBridge help with RTM?

The MedBridge RTM 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.

In order to help our clinicians bill against these codes, MedBridge 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 MedBridge RTM solution.

The MedBridge RTM program, clinicians can track patient device onboarding and the time spent reviewing the resulting data. MedBridge also provides patient data monitoring and maintains all of the required auditable documentation. If you’re interested in using the MedBridge RTM solution at your organization, learn more and request a demo.

Does MedBridge 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). The MedBridge Go App and MedBridge Patient Portal were reviewed by an independent party and determined to meet the FDA’s definition of software as a medical 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. However, inpatient facilities can use MedBridge to update the program as the patient is leaving the facility and transitioning to outpatient services. They can also 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, while also earning 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?

RTM is available to all qualified health care practitioners who are not eligible to independently bill for evaluation and management. This includes PTs, PTAs, OTs, COTAs, and more.

What are the new RTM codes and how are they billed?

There are 5 new 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 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.
• More information: How do I review patient enrollment activity?

Device Supply (CPT Codes 98976 and 98977)

• What is covered: 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, each 30 days.
  
  • 98977 refers to monitoring of the musculoskeletal system
  • 98976 refers to monitoring of the respiratory system
• 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 schedule recordings and/or programmed alerts transmitted in a 30 day period.
• More information: How do I review patient engagement activity?
  

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. Log your time as you go, and at the end of the month, if you’ve spent at least 20 minutes completing these activities and had one interactive communication, you can be reimbursed for that time via this code.
• 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.
  • Health care professional time includes time spent reviewing patient activity, responding to messages, updating HEP programs, and communicating with patients interactively. Refer to your organization’s guidelines to ensure you know what activity to log and submit for reimbursement.
• More information: How do I review care team and provider treatment activity?
  

For more detailed information about each CPT code, please refer to this article: What are the new RTM CPT codes?

Learn how to use MedBridge to generate a billing report for each billing code.

How do I know when 16 days of activity have been completed by my patient?

You can use the RTM Reporting page 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, engaged with education resources, messaged clinician, read message, loaded an exercise or education video, completed a survey.

For more information, refer to the Data Definitions tab on the RTM Reporting page. 

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 conversations time is not being used towards billing other codes). You can log any interactive communication that occurs from the RTM Activity Log on the patient’s profile, making it easy to know when you’ve met this threshold. 

Are there differences in how RTM is handled for facilities and non-facilities? 

Depending on how your clinic or department is designated, either as a facility or a non-facility, your billing process will vary. The codes you can bill along with how much you can be reimbursed vary based on which billing system you use: 

• For facility-based providers billing the Outpatient Prospective Payment System, bill codes 98975, 98976, and 98977. Codes 98980 and 98981 are unavailable.
• For non-facility providers billing the Medicare Physician Fee Schedule, all 5 codes codes described in this article can be billed. 

What payers will reimburse for RTM billing codes?

At this time, only Medicare has confirmed they will reimburse for RTM billing codes. However, there has been some indication that other payers may reimburse for RTM in some regional areas and/or in the future. Work with your organization to determine if any additional payers are reimbursing for RTM.

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 and 98977 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 starts towards the end of the month, and I am not able to record 16 days of monitoring within the same month to bill for 98976/98977, 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?

Based on our interpretation of the guidance provided by CMS and AMA, 98975 is independent of 98977. The two codes can be considered and billed for individually, and 98977 does not need to be fulfilled in order for you to bill 98975. 

Furthermore, in 2022, it was proposed that these codes be revised to explicitly state that these two codes are dependent on each other, but ultimately CMS did not include that update in their 2023 final rule. 

98975 refers to the provider setting up the device, educating, and setting expectations for use of the device with the patient and/or caregivers. Once the patient logs in and sets up their device, they have the ability to use the device, so the code starts to become eligible. 16 days after that patient first logs in, you can bill for 98975.

98977 requires schedules or programmed alerts to be transmitted on 16 out of 30 days. Therefore, the patient needs to log in to MedBridge and complete some activity in order for a day to be counted towards the 16 day threshold. So while you can bill for 98975 if the patient has access to their device for 16 days, you cannot bill for 98977 until the patient has provided data on 16 days.

As always, defer to your organization’s guidelines as their interpretation of the CMS code may differ.

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.