Physicians and eligible qualified healthcare professionals, are permitted to bill RTM as general medicine services. A physician or other qualified healthcare professional is defined in the CPT Codebook as “an individual who is qualified by education, training, licensure/regulation (when applicable) and facility privileging (when applicable) who performs a professional service within his/her scope of practice and independently reports that professional service.”

Accordingly, RTM codes are available for use by physical therapists (PT) and occupational therapists (OT).

In the final rule, CMS stated the primary billers of RTM codes are projected to be physiatrists, nurse practitioners, and physical therapists. The new RTM codes, classified as general medicine codes, should open up opportunities for therapists, psychologists, and other eligible practitioners who cannot currently bill for RPM (as RPM is an E/M code).

CPT code 98980 requires a minimum of 20 minutes of time in a month, dedicated to remote therapeutic monitoring treatment management of the patient. This time must also include at least one interactive communication with the patient/caregiver during the month (e.g., via phone or video).

CPT code 98981 has the same requirements as CPT code 98980, except is it used for additional 20 minutes per month, as an add-on code.

Yes, the clinical use cases eligible for device supply reimbursement under RTM are limited to these areas. The RTM device supply code 98977 is similar to the RPM device supply code (99454), but not identical. The RTM device supply code descriptor indicates far more limited clinical use cases. Namely, 98977 is only for transmissions to monitor the musculoskeletal system.

Code 98975 may be billed once per episode of care. An episode of care begins when the remote therapeutic monitoring service initiates and ends with the attainment of targeted treatment goals.

Codes 98977 may be billed once per 30 days.

Code 98980 may be billed once per calendar month regardless of the number of therapeutic monitoring modalities performed in a given calendar month.

Code 98981 may be billed once per calendar month for each additional 20 minutes completed within such month.

CPT code 98977 requires the RTM device to monitor at least 16 days of data per each 30-day period, in total.

Yes.

CMS stated that self-reported/entered data may be part of the non-physiologic data for purposes of RTM codes.  (“Reportedly, RTM data can be patient reported, as well as digitally uploaded while RPM requires that data be physiologic and be digitally uploaded.”).  RTM codes still require the device used to meet the FDA’s definition of a medical device, self-reported RTM data via mob classified as Software as a Medical Device (SaMD) will qualify for reimbursement. This differs from RPM codes, which require the device to digitally (automatically) record and upload patient physiologic data (i.e., data cannot be patient self-recorded, self-reported, or entered manually into the device).