Remote Therapeutic Monitoring and Chronic Care Management Frequently Asked Questions

This document was prepared by our legal team at Nixon Gwilt Law to help you understand the scope of RTM and CCM.

Please note: The information in this document does not constitute legal advice to the reader, nor is it a guarantee of reimbursement for any claims.

Remote Therapeutic Monitoring (“RTM”) uses digital technologies to gather non-physiologic data from patients in one location (e.g., their home) and transmit that information to healthcare providers in another location (e.g., their doctor’s office) for analysis. RTM devices collect various forms of health data, including respiratory system status, musculoskeletal system status, therapy/medication adherence, and therapy/medication response to monitor patients’ respiratory or musculoskeletal systems. Providers can use this data to monitor patients’ health conditions, provide recommendations, and/or make changes to a patient’s care plan.

The final 2022 Medicare Physician Fee Schedule (“2022 Rule”) released on November 2, 2021, created a new family of five CPT codes for RTM and RTM Treatment Management services (CPT codes 98975, 98976, 98977, 98980, and 98981) that resemble the services and code structure of the codes used for Remote Physiologic Monitoring (“RPM”) that were finalized in 2019 and expanded in 2020.

Centers for Medicare and Medicaid Services (“CMS”) noted in the 2022 Rule that although there are similarities between RTM and RPM, there are two primary differences: (1) the RTM codes, unlike the RPM codes, have not been designated as “care management services” and therefore the clinical labor component of the codes must be provided under the direct supervision of the billing practitioner (instead of general supervision), and (2) RTM non-physiologic data can be patient self-reported, as well as digitally uploaded, while RPM requires that data be physiologic and digitally uploaded. During the PHE, direct supervision may be provided through virtual direct supervision, meaning the billing practitioner must be immediately available by virtual means while clinical staff are providing monitoring services.

RTM services can be beneficial to patients, providers, and healthcare facilities. RTM expands the types of practitioners who can furnish, and bill monitoring services and helps patients by allowing them to self- report key pieces of information that their care teams can use to correlate between therapeutics used and treatment efficacy. This can lead to quicker, more tailored, and more effective treatments, increasing patients’ quality of life and decreasing their healthcare costs. RTM can help physicians and health care facilities reduce the number of hospitalizations, readmission rates, and patients’ length of stay by identifying adverse health events sooner. All of these factors can help reduce the overall cost of care.

RTM services often go hand-in-hand with Chronic Care Management (“CCM”) services. The 2022 Rule added one new CCM code (CPT code 99437) to the existing complex care management code set (CPT codes 99490, 99493, 99491, 99487, and 99489). CCM services consist of establishing, implementing, revising, or monitoring a care plan for a patient with two or more chronic condition(s). CCM services typically focus on advanced primary care aspects such as a continuous relationship between the patient and a designated care team member, providing support for chronic diseases, 24/7 access to care, preventive care, and timely sharing of health information, all of which are often performed outside the face-to-face context. CCM patients often require a significant amount of attention and RTM can help practitioners keep track of their CCM patients’ condition(s) on an ongoing basis without requiring the patient to travel to the physician’s office.

RTM Codes

The descriptors for the RTM codes are as follows:

CPT code 98975 (*$18): (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)

CPT code 98976 (*$54): (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 to monitor respiratory system, each 30 days)

CPT code 98977 (*$54): (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 to monitor musculoskeletal system, each 30 days)

CPT code 98980 (*$48): (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; first 20 minutes)

CPT code 98981 (*$39): (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; each additional 20 minutes)\

*Please Note: Reimbursement amounts listed represent a national average; exact reimbursement amounts vary by geographic region. Amounts are based on CMS 2022 non-facility pay rate and are subject to change.

RTM Frequently Asked Questions

1. What are the documentation requirements for the RTM codes?

CMS does not require that any documentation be submitted along with claims submitted for RTM. By virtue of the submission of the claim to a payer, a billing practitioner is attesting that the service was provided correctly and was medically necessary — the same as holds true for any claim submitted for any service. For internal record-keeping, and consistent with the code descriptors outlined above, billing practitioners may consider documenting and/or utilizing software that can help track the following requirements for each of the RTM codes:

All RTM codes

  • Verbal patient consent must be documented in the patient’s medical record at the time of service (can also be written consent)

  • Date/time consent obtained CPT code 98975

  • Initial device set-up and patient education complete

  • Date/time of set-up and patient education

  • May only be reported once per episode of care

CPT code 98976

  • Device(s) meets CMS/FDA requirements

  • Connected respiratory device(s) supplied to patient

  • At least 16 separate days of data readings transmitted to the provider in the relevant 30-day period

CPT code 98977

  • Device(s) meets CMS/FDA requirements

  • Connected musculoskeletal device(s) supplied to patient

  • At least 16 separate days of data readings transmitted to the provider in the relevant 30-day

    period

CPT code 98980

  • At least one live, interactive communication completed during the calendar month

  • 0-20 minutes of physician/ other qualified health care professional (“QHCP”) time or supervised clinical staff time spent towards RTM services during the calendar month

CPT code 98981

  • At least one live, interactive communication completed during the calendar month

  • Each additional 20 minutes (beyond initial 20 minutes) of physician/QHCP time or supervised

    clinical staff time spent towards RTM services during the calendar month

2. Is there a recommended billing format for the RTM Codes?

Providers should follow current billing practices and ensure that all the requirements for each code are met, such as documenting medical necessity for ordering RTM services and patient consent in the medical record.

3. Are there patient co-pays for the RTM codes?

Yes. As with all Medicare services, patients are responsible for all applicable co-payments and cost-sharing amounts. Medicare Part B beneficiaries are typically responsible for a 20% co-pay each time a code is billed. During the PHE, providers may opt to waive the collection of patient copays.

4. Who can bill Medicare directly for RTM services?

Providers who are eligible to bill Medicare directly for their services and whose scope of practice includes RTM services are eligible to bill for RTM services. This may include:

• Physicians

  • Anesthesiology Assistants

  • Certified Nurse Midwives

  • Certified Registered Nurse Anesthetists

  • Clinical Nurse Specialists, Clinical Social Workers

  • Nurse Practitioners

  • Occupational Therapists in Private Practice*

  • Physical Therapists in Private Practice*

  • Physician Assistants

  • Psychologists

  • Qualified Audiologists

  • Speech Language Pathologists in Private Practice*

  • Registered Dietitians or Nutrition Professionals

In all cases, practitioners must practice in accordance with applicable state law and scope of practice laws.

*RTM treatment management services (CPT codes 98980 and 98981) can be furnished by therapists who are working in rehabilitation agencies and CORFs, but not when a patient is inpatient in a hospital or SNF.

5. Can RTM and RPM be billed at the same time for the same patient?

No. The American Medical Association’s CPT Manual (the “CPT Manual”) states that RTM and RPM should not be billed for the same patient in the same month.

6. Does RTM require a certain number of readings?

Yes. Although the 2022 Rule is silent on the matter, the CPT Manual states that the RTM device codes (CPT codes 98975, 98976, and 98977) should not be reported if monitoring is less than 16 days. Please note that CMS and auditors generally defer to language in the CPT Manual when the Rule is silent. There is no prohibition, however, on billing the treatment management services codes (CPT codes 98980 and 98981) if less than 16 days of transmissions have occurred, as long as the required 20 minutes of time has been accrued and all other billing requirements are met.

7. Did CMS designate RTM as “Care Management Services” like they did with RPM?

CMS did not designate the RTM code set as “Care Management Services”. This means that when RTM services are provided incident-to the billing practitioner, clinical staff must be supervised under direct supervision, meaning the billing practitioner must be in the same physical office location as the clinical staff. During the PHE, direct supervision may be provided through virtual direct supervision, meaning the billing practitioner must be immediately available by virtual means while clinical staff are providing monitoring services.

8. Can providers use “clinical staff” to provide RTM services?

Although “clinical staff” is not included in the RTM code descriptors, CMS clarified that when the billing practitioner’s benefit allows services to be furnished incident-to their professional services, RTM services can be provided by clinical staff under direct supervision. The following practitioners’ benefits allow for billing incident to their professional services: Physicians, Physician Assistants, Nurse Practitioners, Clinical Nurse Specialists, Certified Nurse Midwifes, and Clinical Psychologists. During the PHE, direct supervision may be provided through virtual direct supervision, meaning the billing practitioner must be immediately available by virtual means while clinical staff are providing monitoring services.

9. What constitutes “clinical staff” for purposes of RTM?

If the RTM services are performed as “not therapy services”, meaning the services are being performed by a physician or QHCP outside of a therapy plan of care, a clinical staff member is defined in the CPT Manual as “a person who works under the supervision of a physician or QHCP and who is allowed by law, regulation, and facility policy to perform or assist in the performance of a specified professional service, but who does not individually report that service.” This means that the type of personnel that qualify as “clinical staff” for purposes of RTM varies by state law and providers should look to applicable scope of practice laws in the patient’s state to determine who can and cannot provide monitoring services.

10. What does “non-physiologic” mean for purposes of billing the RTM codes?

CMS does not specifically define “physiologic” data for RPM or “non-physiological” data for RTM. In the 2022 Rule, CMS gives examples of health conditions where non-physiologic data can be collected, including musculoskeletal system status, respiratory system status, therapy (for example, medication) adherence, and therapy (for example, medication) response. Providers should use their professional judgment in determining what constitutes “non-physiologic” or “therapeutic” for purposes of RTM.

11. What types of devices can be used for providing RTM services?

CPT codes 98976 and 98977, billed for the ongoing supply of RTM devices, provide reimbursement for devices that monitor the respiratory (98976) or musculoskeletal (98977) system.

For both RTM and RPM services, the CPT Manual states that devices used must be “medical devices” as that term is defined by the U.S. Food and Drug Administration (“FDA”) in the Food, Drug & Cosmetics Act (“FD&C Act”). This does NOT mean that a device used must necessarily go through the FDA “clearance” or “approval” process for reimbursement purposes, but the FDA may require this depending on the device’s status under applicable FDA pathways. Importantly, the FDA’s definition of a “medical device” includes certain software functions. More information regarding medical devices under the FD&C Act can be found on the FDA website.

12. Can patients self-report therapeutic data for RTM?

Yes. RTM data can be patient self-reported or automatically transmitted through a SaaS platform that is classified by the FDA as Software as a Medical Device (“SaMD”).

CCM Codes

The CPT Code Manual describes each of the CCM codes as follows:

CPT Code 99490 ($62*): Chronic care management services, first 20 minutes of clinical staff time directed by a physician or other qualified health care professional, per calendar month, with the following required elements:

  • multiple (two or more) chronic conditions expected to last at least 12 months, or until the death of the patient;

  • chronic conditions place the patient at significant risk of death, acute exacerbation/decompensation, or functional decline;

  • comprehensive care plan established, implemented, revised, or monitored.

CPT Code 99439 (add-on code to 99490) ($47*): Chronic care management services, each additional 20 minutes of clinical staff time directed by a physician or other qualified health care professional, per calendar month (List separately in addition to code for primary procedure)

CPT Code 99491 ($83*): Chronic care management services, provided personally by a physician or other qualified health care professional, first 30 minutes of physician or other qualified health care professional time, per calendar month, with the following required elements:

  • multiple (two or more) chronic conditions expected to last at least 12 months, or until the death of the patient;

  • chronic conditions place the patient at significant risk of death, acute exacerbation/decompensation, or functional decline;

  • comprehensive care plan established, implemented, revised, or monitored.

CPT Code 99437 (add-on code to 99491) ($59*): Chronic care management services each additional 30 minutes by a physician or other qualified health care professional, per calendar month (List separately in addition to code for primary procedure)

Complex Chronic Care Management (“CCCM”) Codes:

CPT Code 99487 ($103*): Complex chronic care management services, with the following required elements:

  • multiple (two or more) chronic conditions expected to last at least 12 months, or until the death of the patient,

  • chronic conditions place the patient at significant risk of death, acute exacerbation/decompensation, or functional decline,

  • establishment or substantial revision of a comprehensive care plan,

  • moderate or high complexity medical decision making; [sic]

  • 60 minutes of clinical staff time directed by a physician or other qualified health care professional, per calendar month.

CPT Code 99489 (add-on code to 99487) ($68*): each additional 30 minutes of clinical staff time directed by a physician or other qualified health care professional, per calendar month (List separately in addition to code for primary procedure).

CCM Frequently Asked Questions

1. Are there patient co-pays for CCM services?

Yes. As with all Medicare services, patients are responsible for all applicable co-payments and cost-sharing amounts. Medicare Part B beneficiaries are typically responsible for a 20% co-pay each time a code is billed. During the PHE, providers may opt to waive the collection of patient copays.

2. Is there a recommended billing format for the CCM codes?

Providers should follow current billing practices and ensure that all the requirements for each code are met, such as documenting medical necessity and patient consent in the medical record.

3. Can the same types of “clinical staff” who provide RPM services provide CCM services?

Similar to RPM, the type of personnel that qualify as “clinical staff” for purposes of CCM will vary by state law and providers should look to applicable scope of practice laws in the patient’s state to determine who can and cannot provide care to patients with complex diseases. Due to the nature of caring for patients with complex diseases, CCM patients often require care from providers with a higher-level education and scope of practice than is needed to provide traditional RPM monitoring services.

Please note: The information in this document does not constitute legal advice to the reader, nor is it a guarantee of reimbursement for any claims.

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