What Are the Rules for Billing Remote Therapeutic Monitoring Codes?

Remote monitoring of patients is a way for healthcare providers to access information about patients who are not in the provider’s presence. Healthcare providers gather data from their patients without requiring the patient to visit a doctor’s office and submit it to on-site testing.

Remote patient monitoring (RPM) is an established part of medical practice and billing. Billings for RPM have generally been limited to the collection and monitoring of specific data using medical devices, followed by virtual consultations with patients who are being monitored.

For example, patients who measure their blood pressure, pulse rate, or blood glucose at home use devices that transmit that information to their doctor. If the data alerts the doctor to an emerging or urgent healthcare problem, the doctor can contact the patient with advice or to schedule an office visit.

Remote monitoring of patients offers the promise of better healthcare at a reduced cost. Because the patient does not need to meet the doctor in person, RPM results in fewer office visits. Virtual care management meetings allow the patient to receive medical advice from the comfort of his or her own home. Staffing needs are reduced because a provider can manage health care without the need for staff to meet with the patient, bring the patient to an examination room, and juggle patients because of missed or late appointments.

For some time, Medicare and private insurance companies have offered reimbursement to healthcare providers who implement a system for remote health monitoring of their patients. To assure that physicians are reimbursed for the time they spend reviewing data that was gathered remotely, the government agency that handles Medicare and Medicaid reimbursement — the Centers for Medicare & Medicaid Services (CMS) — established CPT codes for remote patient monitoring.

The American Medical Association , together with CMS, creates and maintains 5-digit codes that describe each service or procedure for which a healthcare provider might bill. Insurance companies and government agencies rely on those codes to determine the rate of reimbursement the provider will receive for each billed procedure or service.

The CPT codes for RPM typically cover monitoring of physiological measurements, including blood pressure, pulse oximetry, and respiratory flow rate. One billing code applies to a patient’s initial entry into an RPM program. The code covers the time spent demonstrating the data collection device(s) to the patient and explaining how often the patient should take a measurement.

A second CPT code covers 30 days of monitoring data, provided the patient takes measurements at least 16 times during the 30-day period. The code also covers the physician’s amortized cost of the data collection equipment that the physician supplies to the patient.

A third CPT code covers 20 minutes of remote contact with a patient by the provider, including doctors and care managers, to discuss healthcare management based on the collected data. That code is billable monthly. A fourth CPT code covers additional time spent in virtual interactive patient care during the month in 20-minute increments.

The success of remote monitoring persuaded CMS to expand reimbursement to monitoring of data that was not covered by its initial approval of CPT codes for RPM. The CMS has authorized a new set of CPT codes that govern expanded services that healthcare providers offer remotely. 

Remote therapeutic monitoring (RTM) codes cover services that are similar to RPM but include a broader range of health conditions. At the moment, RTM includes monitoring of respiratory and musculoskeletal conditions. 

The CMS rules governing reimbursement of RTM differ from RPM rules with regard to the kind of data that the provider monitors and the ways in which data is collected. The rules also differ with regard to the kinds of providers who are eligible for reimbursement.

Like RPM, data collected by medical devices is a part of RTM. For example, a physician may provide an inhaler to a patient with a pulmonary condition (such as COPD) that monitors when and how often during the day the patient uses the inhaler, how many puffs/doses the patient uses each time, and the pollen count and environmental factors at the time the patient uses the inhaler. The physician would use that information to determine the effectiveness of treatment, the environmental conditions that appear to trigger respiratory distress, and the possible deterioration of the patient’s condition. 

However, RTM also includes certain self-reported data. While coverage for RPM depends on the use of medical devices that record and upload the patient’s physiological data, some RTM data can be self-reported, entered manually into a device, and uploaded by the patient.

The new rules allow reporting of data that can’t be recorded by a device, such as pain levels and reactions to medication. At this point, the list of data that can be collected appears to be illustrative rather than exhaustive. It is not entirely clear how much therapeutic data (i.e., data that is not measured by a medical device) can be included in reimbursable RTM data monitoring.

The other key difference between RTM and RPM is that RTM is classified as general medicine, while RPM is classified as Evaluation and Management services. Classifying RTM as general medicine makes it possible for additional Qualified Health Care Professionals (QHCPs) to apply for reimbursement for remote monitoring services. The CMS anticipates that most billings using RTM codes will be for services provided by nurses and physical therapists.

The CMS has authorized five new CPT codes to describe and seek reimbursement for RTM procedures. Those codes will go into effect on January 1, 2022.

To some extent, the codes parallel RPM codes. The first code addresses the initial set-up of RPM, including instructions on when and how to record data and how to upload the data to the provider’s system. 

The next two codes address monitoring during a 30-day period. Monitoring includes a review of recorded data as well as the patient’s adherence and response to therapy. One code applies to the monitoring of the respiratory system and the other applies to the monitoring of the musculoskeletal system.

The last two codes apply to interactive communications with the patient by a physician or other QHCP. The first code describes a 20-minute session while the second code applies to each additional 20-minute increment.