Remote Therapeutic Monitoring Debuts in CMS 2022 Proposed Rule

Update: The 2022 Medicare Physician Fee Schedule (PFS) final rule further defined remote therapeutic monitoring (RTM), including finalizing five RTM CPT general medicine codes, but left many questions unanswered while also limiting coverage for these codes. You can learn more about the current state of RTM in this Physicians Practice column discussing the 2022 final rule written by Prevounce Co-Founder Daniel Tashnek. We anticipate receiving more information and clarification concerning RTM in the 2023 PFS proposed and final rules.  

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The Centers for Medicare & Medicaid Services (CMS) has issued its 2022 Medicare Physician Fee Schedule proposed rule. Within it are some potentially significant developments concerning remote therapeutic monitoring, which we will discuss below.

RTM is a series of five treatment management service codes created by the CPT Editorial Panel in October 2020, with a target effective date of Jan. 1, 2022. It is rare for CMS to adopt coverage for new CPT services right away, but per the proposed rule, it looks like that is exactly what CMS is planning to do for RTM.

What is Remote Therapeutic Monitoring?

Generally speaking, the remote therapeutic management codes are designed as direct mirrors of the remote patient monitoring CPT codes, with RTM intended for the management of patients utilizing medical devices collecting non-physiological data. Despite the planned CMS coverage of remote therapeutic monitoring as outlined in the proposed rule, it's important to note that RTM is a concept where the specific requirements are still largely undefined. We have the CPT descriptions from the American Medical Association (provided above) and now what we'd describe as fairly vague, non-canonical musings by CMS in the proposed rule comments. We expect more information on these RTM codes in the coming months and will be sharing what we learn as details become clearer, but here's a quick summary of what CMS seems to be proposing concerning RTM.

How Remote Therapeutic Management and Remote Patient Monitoring Are Different

CMS describes two major differences between RPM and RTM.

First is that providers that can't bill for RPM may be able to bill for RTM. In the proposed rule, Medicare points out that the way the AMA designated the RTM codes as non-evaluation and management (E/M) does not allow Medicare to designate them as general supervision care management codes, hence the reason they looking for comments about ways to "remedy" this disconnect.

Second concerns the nature of the data collected, more specifically therapeutic for RTM versus physiological for RPM. RTM can be used for non-physiological medical devices like those used to support medical adherence (e.g., smart pill reminder systems) and medication symptom/adverse reaction applications. Essentially, any information that a medical device — including software that fits the definition of a medical device — can collect that is not physiological can be collected and billed for under RTM.

Proposed Remote Therapeutic Monitoring Coding and Coverage and Coding

The remote therapeutic monitoring codes are described as follows:

• CPT code 989X1 — 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 989X2 — 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 989X3 — 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 989X4 — 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 989X5 — 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 (List separately in addition to code for primary procedure)

Of these, CPT 989X1, CPT 989X2, and CPT 989X3 are considered practice expense-only codes while CPT 989X4 and CPT 989X5 are professional work codes.

Considering these remote therapeutic monitoring treatment management service codes are supposed to take effect next year, it's not surprising to see them highlighted in the 2022 proposed rule.

Remote Therapeutic Monitoring: Proposed Rules and Requests

Here are seven of the most significant takeaways about RTM from the 2022 proposed rule.

1. CMS is proposing to apply the RVS Update Committee (RUC) recommended work RVU of 0.62 for CPT 989X4 and the RUC-recommended work RVU of 0.61 for its add-on code, CPT 989X5, as a means of maintaining parity with the two remote patient monitoring (RPM) treatment management codes (CPT 99457 and CPT 99458) upon which the two RTM codes are based.
2. CMS is proposing the RUC-recommended direct practice expense (PE) inputs for CPT 989X4 and CPT 989X5 — the two treatment management codes — without refinement.
3. CMS is proposing to refine the direct PE inputs for the three PE-only codes (CPT 989X1, CPT 989X2, and CPT 989X3).
4. CMS is proposing to value the PE for CPT code 989X1 by crosswalking to the PE RVU for remote patient monitoring CPT code 99453 upon which the RTM CPT code was based.
5. CMS is proposing to value the PE for CPT 989X2 and CPT 989X3 by crosswalking to the PE RVU for comparable RPM CPT code 99454, a code that includes payment for the medical device used to collect and transmit data. CMS notes that the only input to CPT 989X2 is a monthly fee of $25, which would not be paid as a direct cost under the Physician Fee Schedule.
6. CMS is seeking comment on the typical type of devices and associated costs of those devices that might be used to collect the various kinds of data included in the code descriptors (e.g., respiratory system status, musculoskeletal status, medication adherence, pain) for the RTM services.
7. Due to how the RTM codes are constructed, practitioners who are not physicians or non-physician providers (e.g., physical therapists) would not presently be able to bill the RTM codes. CMS is seeking comment on how to remedy the issues related to the RTM code construction to permit such billing.

Here is the full 2022 Medicare Physician Fee Schedule proposed rule.

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