The Centers for Medicare & Medicaid Services (CMS) has proposed a new category of digital health services—Remote Therapeutic Monitoring (RTM)—to complement the existing suite of Remote Physiological Monitoring (RPM) codes covered under Medicare. The new codes, part of the proposed 2022 Physician Fee Schedule, are intended to expand the scope and reach of digital health technologies to reimburse monitoring of non-physiologic data.
The creation of new RPM codes at the beginning of 2019 was a major step forward in digital health coverage to improve care delivery, outcomes, and cost management. Since that time, the American Medical Association’s (AMA) Digital Medicine Payment Advisory Group has developed, and CMS adopted, additional codes for remote monitoring services. The recent RTM proposal recognizes the benefit of remote monitoring and continues to foster the use of digital health tools to give clinicians a more comprehensive data set of their patients’ health conditions.
RTM refers to a suite of codes created by the AMA in October 2020 and valued by its RVS Update Committee in January 2021. The codes are currently numbered as CPT 989X1, 989X2, 989X3, 989X4, and 989X5. The structure and nature of RTM services resemble RPM services. (Read more about RPM rules here and here).
The RTM code descriptions are as follows:
While there are similarities between the RPM and RTM codes, CMS identified some key differences in the nature of the data collected, how the data is collected, and which clinicians are eligible to bill for RTM services.
The first difference is the nature of the data to be collected. RTM codes monitor health conditions including, but not limited to, musculoskeletal system status, respiratory system status, therapy adherence, and therapy response, and as such, allow non-physiologic data to be collected. Compared to RPM, the RTM codes offer the promise of broader use cases and applications in patient care. The list of RTM health conditions identified in the code descriptors is meant to be illustrative and not exhaustive (hence the use of “e.g.”). In the proposed PFS rule, CMS added the word “(medication)” – “therapy (medication) adherence, and therapy (medication) response” – but that word is not contained in the CPT code descriptors. It is unclear what AMA or RUC materials CMS relied upon when inserting the word ‘medication’ in its PFS commentary.
Here’s a hypothetical example of how RTM might potentially be used under the proposed rule:
An asthmatic patient is prescribed a rescue inhaler equipped with an FDA-approved medical device that monitors when the patient uses the inhaler, how many times during the day the patient uses the inhaler, how many puffs/doses the patient uses each time, and the pollen count and environmental factors that exist in the patient’s location at that time. This is non-physiologic data. The data is then used by the treating practitioner to assess the patient’s therapeutic response and adherence to the asthma treatment plan. This can enable the practitioner to better determine how well the patient is responding to the particular medication, what social or environmental factors affect the patient’s respiratory system status, and what changes could be made to improve the patient’s health.
A second difference is what clinical use cases are eligible for device supply reimbursement under RTM. The two RTM device supply codes (989X2, 989X3) are similar to the RPM device supply code (99454), but not identical. CPT code 99454 does not restrict the clinical or biological systems being monitored, although the data must be physiological. In contrast, the two RTM device supply code descriptors themselves indicate far more limited clinical use cases. Namely, 989X2 is only for transmissions to monitor respiratory system, whereas 989X3 is only for transmissions to monitor musculoskeletal system. The current RTM device supply codes do not target other systems (e.g., neurological, vascular, endocrine, digestive, etc.).
A third difference is how the device collects data. Both RTM and RPM require the use of a medical device. However, according to CMS’ commentary, RTM data can be self-reported by the patient, as well as digitally uploaded via the device. In contrast, RPM requires the device to digitally (that is, automatically) record and upload patient physiologic data (i.e., data cannot be patient self-recorded, self-reported, or entered manually into the device). It is unclear what AMA or RUC materials CMS relied upon when determining the RTM codes allow a patient to self-report the data, particularly as that interpretation does not mirror RPM device requirements.
A fourth difference is which clinicians can order and bill for RTM services. Based on its review of the AMA documents, CMS opined the primary billers of RTM were intended to be nurses and physical therapists. The idea being the new RTM codes would allow practitioners who cannot bill RPM codes to furnish and bill for services that look similar to those of RPM. (RPM is an E/M service and physical therapists cannot bill E/M services.) The RTM codes, accordingly, are classified as general medicine codes and not E/M codes. However, CMS’ proposed rule notes certain inconsistencies, described below:
Providers, technology companies, and virtual care entrepreneurs interested in RPM should consider providing comments to the proposed rule. CMS is soliciting comments on the proposed rule until 5:00 p.m. on September 13, 2021. Anyone may submit comments—anonymously or otherwise—via electronic submission at this link. When commenting, refer to file code CMS-1751-P in your submission. Alternatively, commenters may submit comments by mail to:
If submitting via mail, please be sure to allow time for comments to be received before the closing date.
The CMS proposed rule advances the ability of clinicians to use remote monitoring technologies to improve the patient care experience, but the technical details still need to be ironed out. We will continue to monitor CMS for any rule changes or guidance that affect or improve RPM (and now RTM) opportunities.
For more information on telemedicine, telehealth, virtual care, remote patient monitoring, digital health, and other health innovations, including the team, publications, and representative experience, visit Foley’s Telemedicine & Digital Health Industry Team.