Proposed Physician Fee Schedule Adds Coverage For Remote Therapeutic Monitoring

Rivkin Radler LLP

Rivkin Radler LLP

The proposed 2022 Medicare Physician Fee Schedule released on July 13 by the Centers for Medicare & Medicaid Services (CMS) includes a new category of CPT codes for “remote therapeutic monitoring” (RTM). The new codes are in addition to the set of codes introduced in 2019 for remote physiological monitoring, usually called remote patient monitoring (RPM).

The new RTM codes list respiratory system status, musculoskeletal system status, therapy (medication) adherence, and therapy response as examples of what can be monitored and reimbursed, and include:

  • CPT code 989X1: initial set-up and patient education on use of equipment
  • CPT code 989X2: 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: 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: 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: same as above for each additional 20 minutes

The new RTM codes will give healthcare providers more opportunities to be reimbursed for remote monitoring services. CMS’s commentary suggests that nurses, physical therapists, and other types of practitioners who cannot currently bill for RPM will be able to use the new codes, in addition to physicians. While the collection of RPM data must be automated, patients will be able to self-report and manually upload RTM data.

CMS will be accepting public comments on the rule until September 13.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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