CMS has started to pay for remote therapeutic monitoring (RTM) by physical and occupational therapists. RTM allows for monitoring of HEP compliance, therapy response and pain level. So, Medicare will now pay therapists for remotely monitoring and managing a patient’s HEP.
CPT Codes. PTs and OTs can use the following four RTM codes: 98975, 98977, 98980 and 98981. (98976 is for monitoring of the respiratory system.)
- 98975 can be charged for the initial set-up and patient education on use of the RTM device. 98975 can be charged only once per episode of care and only if monitoring occurs over a period of at least 16 days. An episode of care starts when the RTM service is initiated and ends when the targeted treatment goals are achieved. This code covers educating the patient on setting up the device, reviewing the device technology, reviewing the specific exercises prescribed by the PT/OT and answering the patient/caregiver’s questions. When you charge for 98975, document the type of device being used, the specific education and training provided to the patient and/or caregiver and any required set-up. Medicare’s 2022 national payment rate for 98975 is $19.38 but the actual amount paid will vary a bit after Medicare’s geographic payment adjustment.
- 98977 can be charged for supplying an RTM device with scheduled (e.g., daily) recording(s) and/or programmed alert(s). 98977 can be charged only once every 30 days during an episode of care and only if monitoring occurs over a period of at least 16 days. Document the name and description of the monitoring device. Medicare’s 2022 national payment rate for 98977 is $55.72 but the actual amount paid will vary a bit after Medicare’s geographic payment adjustment.
- 98980/98981 can be charged for remote treatment management services requiring at least one interactive communication with the patient and/or caregiver during a calendar month. These services include analysis and interpretation of the data and, based on the interpreted data, using clinical decision making to assess the patient’s condition, communicate with the patient, and oversee, coordinate, and/or modify the patient’s care through shared decision making to achieve established outcomes and goals of care. The interactive communication contributes to the total time, representing only a part of the entire cumulative reported time of the treatment management service.
- In addition to monitoring device–generated therapeutics and data, codes 98980 and 98981 are applicable to patient-provided inputs. These inputs may be either objective or subjective and address signs, symptoms, adherence to therapy, and therapy response (e.g., data generated from patient-reported outcomes surveys, questionnaires, assessments, patient interaction with the device, etc.).
- One (and only one) unit of 98980 can be charged for the first 20 minutes of remote treatment management services each calendar month. Do not report 98980 for services that take less than 20 minutes. One unit of 98981 can be charged for each additional 20 minutes of remote treatment management during a calendar month. As with 98990, one unit of 98981 can be charged only if a full additional 20 minutes of services are provided. A therapist or licensed assistant must perform the 20 minutes of management services to charge for 98980 and 98981. Clinical staff time to e.g., collect and log the data is not counted towards any 98980 or 98981 management time.
- Document the data gathered from the device, the date and time of the patient and/or caregiver interaction, and any decisions made that impact the treatment and plan of care as a result of the monitoring.
- Medicare’s 2022 national payment rate is $50.18 for 98980 and $40.84 for 98981 but the actual amount paid will vary a bit after Medicare’s geographic payment adjustment.
Total Payment. If the provider supplies the device, the total payment for one month of monitoring will be about $166. The $166 consists of $19.38 for the 98975 set up and education, $55.72 for supplying the device, $50.18 for the first 20 minutes of treatment management and $40.84 for the second 20 minutes of treatment management (if necessary). If the episode of care extends beyond 30 days, 98977, 98980 and 98981 can be charged again.
Medical Device. These RTM codes can be used only if the monitoring device qualifies as a “medical device” as defined by the FDA. The definition of medical device is fairly broad. For example, a smart phone or tablet application that helps monitor a patient’s musculoskeletal system status may qualify as a medical device. An explanation of what qualifies as a medical device can be found at https://www.fda.gov/medical-devices/classify-your-medical-device/how-determine-if-your-product-medical-device. Any vendor that is promoting use of its device for RTM should be able to provide a written explanation and a representation that its product qualifies as a “medical device.”
PTAs/COTAs. In addition to PTs and OTs, RTM can be provided by a physical therapist assistant under the supervision of a physical therapist and an occupational therapist assistant under the supervision of an occupational therapist. To satisfy Medicare supervision requirement, the supervising therapist should be in the same office as the assistant. Medicare’s PTA/COTA payment cut does not apply to the 98977 device supply code but it does apply to 98975, 98980 and 98981 if a PTA or COTA provides the RTM services. (CMS’ example of how the PTA payment cut applies to the RTM codes is included at the end of this information.)
Other Payers. Medicare’s payment for RTM basically requires coverage and payment by Medicare Advantage plans but not necessarily commercial or workers compensation plans. Providers will need to verify coverage with each commercial and work compensation payer.
CMS example of how the PTA pay cut applies to RTM
We are also providing a billing example to illustrate how the de minimis standard would be applied for the RTM treatment management services that describe the interactive communications between the therapist and/or therapy assistant and the patient/caregiver during the calendar month. CPT code 98980 represents the first 20 minutes provided in the month while CPT code 98981 reflects each additional full 20-minute unit, so the midpoint rule is not applicable to these codes.
Billing Scenario #AA: The PT and PTA independently provide a total of 80 minutes of RTM services during the month. For purposes of billing 98980: The first full 20 minutes were provided by the PT – therefore, CPT code 98980 is billed without a CQ modifier. For purposes of billing CPT code 98981, the remaining 60 minutes qualifies for billing three 20-minute units, they were furnished as follows:
- PTA ─ 23 minutes of 98981
- PT ─ 37 minutes of 98981
Total = 60 minutes of 98981 (qualifies to bill three 20-minute units). Billing analysis: the 60 total minutes allows three full 20-minute units of CPT code 98981 to be billed:
- One unit is billed with the CQ modifier for 20 minutes of the 23 minutes provided by the PTA (with 3 minutes leftover).
- One unit is billed without the CQ modifier for the PT’s 20 minutes of the 37 minutes – (with 17 minutes left over).
- The final 20-minute unit is billed with a CQ modifier because the PTA’s 3 minutes is greater than 10 percent of the 20-minute total – that is, 3 minutes divided by 20 equals 15 percent which is greater than the 10 percent standard of 2 minutes.
The two device codes, CPT codes 98976 and 98977, are not subject to the de minimis standard, but the devices’ initial set up and patient education on its use represented by CPT code 98975 is subject to the de minimis policy as an untimed code.
