Primary Care Coding Alert

And understand the similarities, differences between RTM and RPM.

Beginning Jan. 1, 2022, you’ll be able to code various remote therapeutic monitoring (RTM) services for the first time. However, before you use the RTM codes, you’ll need to understand the differences between them and the remarkably similar remote physiologic monitoring (RPM) services the AMA introduced in 2019.

Here’s what you need to know.

Ready or Not, Here Come the New RTM Codes

The codes in question are as follows:

• 98975 (Remote therapeutic monitoring (eg, respiratory system status, musculoskeletal system status, therapy adherence, therapy response); initial set-up and patient education on use of equipment)
• 98976 (… device(s) supply with scheduled (eg, daily) recording(s) and/or programmed alert(s) transmission to monitor respiratory system, each 30 days)
• 98977 (… device(s) supply with scheduled (eg, daily) recording(s) and/or programmed alert(s) transmission to monitor musculoskeletal system, each 30 days)
• 98980 (Remote therapeutic monitoring treatment management services, physician or other qualified health care professional time in a calendar month requiring at least one interactive communication with the patient or caregiver during the calendar month; first 20 minutes)
• +98981 (… each additional 20 minutes (List separately in addition to code for primary procedure))

On the surface, they look very similar to some codes you’re probably already familiar with. They are:

• 99453 (Remote monitoring of physiologic parameter(s) (eg, weight, blood pressure, pulse oximetry, respiratory flow rate), initial; set-up and patient education on use of equipment)
• 99454 (… device(s) supply with daily recording(s) or programmed alert(s) transmission, each 30 days)
• 99091 (Collection and interpretation of physiologic data (eg, ECG, blood pressure, glucose monitoring) digitally stored and/or transmitted by the patient and/or caregiver to the physician or other qualified health care professional, qualified by education, training, licensure/ regulation (when applicable) requiring a minimum of 30 minutes of time, each 30 days)
• 99457 (Remote physiologic monitoring treatment management services, clinical staff/ physician/other qualified health care professional time in a calendar month requiring interactive communication with the patient/caregiver during the month; first 20 minutes),
• +99458 (… each additional 20 minutes (List separately in addition to code for primary procedure))

Know the Difference Between Therapeutic and Physiologic Monitoring

One main difference lies in the nature of the data collected and how it is collected. “RTM codes monitor health conditions, including musculoskeletal system status, respiratory system status, therapy (medication) adherence, and therapy (medication) response,” according to the 2022 Medicare Physicians Fee Schedule (MPFS) proposed rule. In other words, RTM services go beyond physiologic data collection to measure the efficacy of a given treatment on a patient’s condition. Because of that, RTM services “allow non-physiologic data to be collected,” the proposed rule continues.

Another difference is that “RPM requires that data be physiologic and be digitally uploaded” while RTM data “can be self-reported as well as digitally uploaded,” per the proposed rule.

But note this similarity. “For both sets of codes, the device used must meet the FDA [Food and Drug Administration] definition of a medical device as described in section 201(h) of the Federal Food, Drug and Cosmetic Act (FFDCA),” the proposed rule notes. This means the device has to be “an instrument, apparatus, implement, machine, contrivance, implant, in vitro reagent, or other similar or related article, including any component, part, or accessory … recognized in the official National Formulary, or the United States Pharmacopeia, or any supplement to them …” (Source: www.fda.gov/regulatory-information/search-fda-guidance-documents/classification-products-drugs-and-devices-and-additional-product-classification-issues).

CMS is currently seeking comment on the typical type, and associated costs, of the device(s) that might be used to collect the various kinds of data included in the RTM code descriptors.

Know the Difference Between Care Management and Therapeutic Management

Another important difference between the RPM and RTM codes lies in their CPT^® code classification. Because the RPM services are evaluation and management (E/M) services, CMS has designated treatment management RPM codes (99457 and +99458) as care management services, which allow general supervision rather than direct supervision for incident to services. The treatment management RTM codes (CPT^® codes 98980 and +98981), because they are not E/M codes, cannot be designated as care management services according to CMS.

What this means: According to the proposed rule, RTM services should only be performed incident to with direct physician supervision. Because only physicians and certain other practitioners are authorized to furnish and bill “incident to” services under Medicare rules, this currently disallows physical therapists and other practitioners who are not physicians or NPPs from reporting the RTM codes.

This could change, though, when the proposed rule becomes finalized later this year.