Remote Therapeutic Monitoring: The Basics
The original RPM codes that debuted in 2018 were restricted to the remote measurement of physiologic data such as pulse oximetry, blood glucose monitoring, and blood pressure measurements. They allowed providers to bill for the time spent in the initial set-up of the monitoring devices, time for collection and interpretation of the transmitted data, and time spent in interactive provider/patient communication about the data and findings.
Unfortunately, because these codes are restricted to physiologic data collection, they do not include monitoring of countless other valuable measurements of patient status. Consider the value of remotely tracking medication/therapy adherence, range of motion during specific exercises, mood scores, food intake, etc.
The five new proposed codes in the Remote Therapeutic Monitoring group seek to partially remedy these gaps by allowing providers to bill for remote monitoring of the respiratory and musculoskeletal systems, as well as patient adherence to prescribed therapies. The code breakdown is as follows:
- One code (989X1) for initial device set-up and patient education in its operation
- Two codes for data collection by the device over the course of 30 days: one for the respiratory system (989X2) and one for the musculoskeletal system (989X3)
- Two codes for the monthly time spent by the provider in interactive communication with the patient/caregiver regarding collected data: one for the first 20 minutes (989X4) and one for each additional 20 min of communication (989X5)
By expanding the type of data that may be collected and interpreted, these new RPM codes will allow monitoring of more components of patient care. For example, a nurse practicing in a respiratory care clinic may be able to fit a patient’s prescribed inhaler with a device that monitors the number of uses and doses taken each day to determine patient response and treatment efficacy.
Who Can Bill RTM Codes?
According to CMS, these new codes are intended to allow billing by providers who were excluded from billing RPM codes but who can still provide valuable remote services—namely, nurses and physical therapists. By extension, it seems reasonable that this list should include other comparable providers like occupational therapists, speech therapists, clinical psychologists, and registered dieticians.
However, the specifics of billing rules for these new codes have not yet been explicitly defined, leading to substantial confusion about who may use them, and for which services. Because the codes are currently written in a manner that restricts their use to the musculoskeletal and respiratory systems, they still exclude the services of many other providers who have the potential to help patients via remote monitoring.
Consider the following cases:
- A neurologic specialist OT who would like to measure neurologic system performance by monitoring a patient’s balance in the home with a wearable device that can detect near falls
- A clinical psychologist who wants to collect and analyze a patient’s daily mood self-score over a period of several months to determine if a medication is impacting their mood as desired
- A registered dietician who would like to review their patient’s weekly food journals to ensure they are observing the recommended diet
Under the current definitions, it appears that none of these cases would be eligible for billing under RTM codes, because these situations involve monitoring of data outside the musculoskeletal and respiratory systems. However, healthcare law experts have posited that some minor adjustments to the verbiage of the RTM codes would allow them to include a wider array of providers and body systems.
In an effort to better define correct usage of the RTM codes, CMS solicited public comments on the codes through mid-September 2021. CMS will use the collected commentary to determine how to clearly define the codes before they officially debut in January 2022, so be on the lookout for the forthcoming finalized 2022 Physician Fee Schedule on the CMS website.
Implications for Outpatient Rehab Providers
What does all this complex coding terminology mean for the average outpatient therapist in clinical practice? The fee schedule final rule should clarify this further, but based on the current details, we can predict the following:
- RTM codes should permit outpatient PTs (and hopefully OTs) to bill for time spent remotely monitoring patient adherence to assigned home programs.
- This monitoring could extend to the use of apps like AC Health.
- The “Activities” section of the AC Health app allows patients to indicate on a calendar the days in which they performed some or all of their home exercises so that therapists may track patient adherence over time.
- If the therapist detects poor adherence to certain portions of a patient’s home program, secure messaging within the app will allow them to gather more information from the patient about difficulty or pain they are experiencing and make immediate modifications to the program as indicated.
- As defined currently, the RTM codes do not allow for “incident to” billing for services provided by clinical staff under the general supervision of therapists.
- This means that therapists cannot bill RTM codes for remote therapeutic monitoring performed by PTAs and COTAs.
- However, experts are hopeful that CMS will modify the codes to mirror the older RPM codes, thereby permitting RTM code billing when monitoring is performed by supervised clinical staff.
While much will remain unclear until the release of the finalized fee schedule for 2022, the potential of these Remote Therapeutic Monitoring codes is significant and exciting. As the healthcare industry continues to increase its use of remote patient care and monitoring, it’s critical that rehabilitation professionals don’t lag behind: request your 30 day free trial of the AC Health app today to start modernizing the way you prescribe and monitor home programs!
Looking for even more ways to maximize the efficiency and quality of your patient care delivery? Click here (need hyperlink) to download your copy of our New Physical Therapist’s Guide to Measuring and Improving the Delivery of Patient Care.