Understanding the New Remote Therapeutic Monitoring CPT Codes

January 3, 2022
 / 
Rick Gawenda
 / 

Effective January 1, 2022, there were 5 new CPT codes to describe remote therapeutic monitoring (RTM). In this article, I will answer the following questions I have been receiving about these new CPT codes.

  1. What are the new CPT codes that describe RTM and what is the description of each of the new RTM CPT codes?
  2. What is the difference between the new Remote Therapeutic Monitoring (RTM) codes and the existing Remote Physiological Monitoring (RPM) codes?
  3. Can physical therapists (PTs), occupational therapists (OTs) and speech-language pathologists (SLPs) bill the RTM codes to Medicare and other insurance carriers and be reimbursed for them?
  4. What types of practices and organizations will be able to bill the RTM codes?
  5. Will the Annual Therapy Threshold and Multiple Procedure Payment Reduction Policy apply to the RTM codes?
  6. If the RTM codes are provided in whole or in part by a physical therapist assistant (PTA) or an occupational therapy assistant (OTA), will the codes require the CQ/CO modifier and therefore, 15% reduction apply?
  7. How much will CMS reimburse for each of the new remote therapeutic monitoring CPT codes?
  8. What CPT codes can be the same day as the RTM codes?
  9. What type of device can I use in order to bill CPT codes 98975, 98976 and/or 98977?
  10. I see that CPT codes 98976 and 98977 at the end of their description each state “each 30 days”. Must I do the remote therapeutic monitoring for the entire 30 days to bill CPT codes 98976 and/or 98977?
  11. I see that CPT code 98980 states “first 20 minutes”. Can I bill this code if I spend less than 20 minutes in a calendar month?
  12. I see that CPT code 98981 states “each additional 20 minutes”. Can I bill this code if I spend less than an additional 20 minutes in a calendar month?
  13. Will Medicare Advantage plans and commercial insurance carriers reimburse the RTM codes if provided and billed by physical therapists, occupational therapists and speech-language pathologists?
  14. Will Medicare Advantage plans and commercial insurance carriers have a patient cost-sharing responsibility on the RTM codes (e.g., co-pay or co-insurance)?
  15. In order to bill CPT codes 98976 and/or 98977, must I supply the medical device that captures the recordings and/or programmed alert(s) transmission to monitor the respiratory system or musculoskeletal system?

Let’s Begin!

Question #1
What are the new CPT codes that describe RTM and what is the description of each of the new RTM CPT codes?

Answer #1

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Question #2
What is the difference between the new Remote Therapeutic Monitoring (RTM) codes and the existing Remote Physiological Monitoring (RPM) codes?

Answer #2

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Question #3
Can physical therapists (PTs), occupational therapists (OTs) and speech-language pathologists (SLPs) bill the RTM codes to Medicare and other insurance carriers and be reimbursed for them?

Answer #3

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Question #4
What types of practices and organizations will be able to bill the RTM codes?

Answer #4

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Question #5
Will the Annual Therapy Threshold and Multiple Procedure Payment Reduction Policy apply to the RTM codes?

Answer #5

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Question #6
If the RTM codes are provided in whole or in part by a physical therapist assistant (PTA) or an occupational therapy assistant (OTA), will the codes require the CQ/CO modifier and therefore, 15% reduction apply?

Answer #6

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Question #7
How much will CMS reimburse for each of the new remote therapeutic monitoring CPT codes?

Answer #7

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Question #8
What CPT codes can be the same day as the RTM codes?

Answer #8

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Question #9
What type of device can I use in order to bill CPT codes 98975, 98976 and/or 98977?

Answer #9

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Question #10
I see that CPT codes 98976 and 98977 at the end of their description each state “each 30 days”. Must I do the remote therapeutic monitoring for the entire 30 days to bill CPT codes 98976 and/or 98977?

Answer #10

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Question #11
I see that CPT code 98980 states “first 20 minutes”. Can I bill this code if I spend less than 20 minutes in a calendar month?

Answer #11

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Question #12
I see that CPT code 98981 states “each additional 20 minutes”. Can I bill this code if I spend less than an additional 20 minutes in a calendar month?

Answer #12

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Question #13
Will Medicare Advantage plans and commercial insurance carriers reimburse the RTM codes if provided and billed by physical therapists, occupational therapists and speech-language pathologists?

Answer #13

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Question #14
Will Medicare Advantage plans and commercial insurance carriers have a patient cost-sharing responsibility on the RTM codes (e.g., co-pay or co-insurance)?

Answer #14

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Question #15
In order to bill CPT codes 98976 and/or 98977, must I supply the medical device that captures the recordings and/or programmed alert(s) transmission to monitor the respiratory system or musculoskeletal system?

Answer #15

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This article is not intended to and does not serve as legal advice or as consultative services, but is for general information purposes only.




All material posted on our website is the intellectual property of Gawenda Seminars & Consulting, Inc. and can’t be used, reproduced, or posted as your own material without the prior written approval of Gawenda Seminars & Consulting, Inc.

This article is not intended to and does not serve as legal advice or as consultative services, but is for general information purposes only.

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  1. Thank you Rick! This resource is super valuable.
    How does Medicare define monitoring for at least 16 days out of the 30 days per month to bill for 98976?
    What is required to show 16 days of monitoring? Thank you !

  2. Can these codes be used in place of telehealth or are they in conjunction with telehealth. I’m trying to find specific examples of how we would bill 98980 and 98981.

  3. In the incident to practice if the PT uses RTM can it still be billed by the physician under the practice?
    On the commercial side if a patient is receiving RTM services is the patient still liable for a copay or since it’s remote over time, the copay doesn’t apply?
    Thank you in advance.

    1. Any questions regarding a patient copay, you would need to contact the insurance carrier. Medicare allows incident-to-billing. Regarding your other insurance carriers, you would need to check if allowed.

  4. Hi Rick
    Is it safe to say that you can bill RTM codes as well as other CPT codes? Meaning you can still see the patient in the clinic for manual and send home with HEP that can be monitored?
    Thank you
    Gerriann

    1. My opinion is 11. We will confirm that with CMS in our comments regarding the CY 2023 Proposed Rule.

  5. Hi Rick, Regarding question 4 above for facility-based outpatient therapy RTM: When I look up the PFS on cms.gov, it appears that CPT 98975/98976/98977 are not reimbursed by CMS in a facility-based setting, only codes 98980 & 98981 are reimbursable. Do you have any further clarification on the why behind this decision? Those 3 RTM codes apparently are only reimbursed in a non-facility setting. Thank You!

  6. I know 98975 and 98977 can only be billed after monitoring occurs over a period of 16 days.

    98975 can only be billed once per care episode.

    98977 can be billed each 30 days.
    1. Is that 30 days defined by the last day of a calendar month?

    98980 (first 20 min) and 98981(each additional 20 min) are timed in a calendar month.

    2. Can minutes carry over to another month? Ex: if RTM is enabled on June 23rd for a client, they obviously won’t have 16 days of data in yet to bill out the first 2 codes above, nor will they have 20 min of monitoring in yet by the end of June. This means no billing in June, correct?

    3. When July’s billing is ready to be pushed out, can you carry forward the minutes from June and add them in towards the first 20? Or does July 1 start a new count on the minutes? And July would be when you’d bill the 98975 and 98977?

    The resources out there are confusing and there are not enough providers doing this yet to get advice. We are aware too that the MPFS proposed rules have some changes so some of our procedures may have to change as well if the new proposed coding goes through to the final rules.
    Thanks

    1. 98977 is each 30 days so that would not be a calendar month the vast majority of times. Minutes sof 98980 an d98981 can’t be carried over since the description states “during the calendar month”.

  7. RPM Questions:
    We have hospital based OP clinics. For remote patient monitoring (RPM), is the patient co-pay waived? Or would the patient be required to pay a co-pay just as if they attended an OP session?
    Would the RPM count as one of the approved visits per POC an payer authorized visits?
    Thank you…..all help is appreciated.

  8. Hi Rick!
    Can 98976 and 98977 be billed on the same day if you are addressing respiratory and musculoskeletal? Thanks!

    1. Currently, there is no NCCI edit that prevents those 2 codes from being billed on the same date of service.

  9. Hi Rick, When monitoring for 16 day of 30 day period, is the monitoring defined as “the count of days from date the patient was enrolled and first accessed the device? or after the patient has accessed and imputed data at least 16 times out of the 30 day period? Thank you!

    1. My interpretation is when they are enrolled and educated in what to track, how to input the data, etc.

  10. To be able to bill 98975, does the patient also have to participate in the RTM within those 16 days? What if we educate, set-up, onboard, but the patient doesn’t end up participating in the RTM. Can we still bill for 98975?

    Thank you so much!

    1. AMA states 98975, 98976 and 98977 are not to be reported if monitoring occurs for less than 16 days.