Regarding the CMS Final Rule, what are the key takeaways for RTM vs RPM in 2023? CMS released the CY 2023 Physician Fee Schedule Final Rule on November 1, 2022. The final rule includes 2,953 pages of detailed policy changes related to remote therapeutic monitoring and remote patient monitoring Medicare reimbursement. This article breaks down the final rule and provides key takeaways for the RTM vs. RPM policy updates, set to begin on January 1, 2023.
Remote Therapeutic Monitoring in 2023
When looking at RTM vs. RPM, remote therapeutic monitoring (RTM) monitors and reports on non-physiological patient data, including medication and exercise adherence, functional status, response to therapy, and respiratory and musculoskeletal activity. RTM data is self-reported, entered manually into an FDA-cleared medical device, and digitally uploaded by patients themselves. Furthermore, FDA-cleared medical devices commonly used to administer patient care include RPM weight scales and remote spirometers.
New revenue streams opened to healthcare providers in November 2022 when The American Medical Association (AMA) created 5 CPT codes for RTM services: 98975, 98976, 98977, 98980, and 98981. The codes are comprised of three practice expense-only codes: 98975, 98976, and 98977, and two codes for treatment management: 98980 and 98981.
Now that we’ve reviewed what remote therapeutic monitoring is, we will provide a quick overview of billing updates for 2023.
RTM vs. RPM: 2023 RTM Billing Takeaways
The 2023 Physician Fee Schedule Final Rule provisions clarify remote therapeutic monitoring services requirements. Though some proposed changes from July 2022 were rejected, overall, there are two key takeaways when it comes to RTM billing in 2023.
- Physicians and certain medical professionals can use CPT codes 98980 and 98981 to bill for services furnished by clinical staff under CMS general supervision requirements.
- CMS finalized the reimbursement rates for the Practice Expense-Only Codes for cognitive behavioral therapy services, to be determined by local Medicare Administrative Contractors (MACs) for 2023.
Further, the following section explains exactly what the 5 RTM CPT codes cover in 2023, including the average reimbursement rate and requirements.
RTM 2023 CPT Code Reimbursement Rates
As of 2022, CMS adopted 5 CPT codes to pay for device setup, collection, interpretation, and processing of remote non-physiological data. The following section explains exactly what the 5 RTM CPT codes cover in 2023, including average reimbursement rate and requirements. These rounded numbers are based on non-facility national averages and vary by region.
98975
This code covers initial setup and patient education on the use of equipment. It can be billed once by one practitioner only when at least 16 days of data have been collected on at least one medical device. The average national payment rate for CPT 98975 is $19.
98976
Billing CPT code 98976 pays for respiratory devices supplied with daily scheduled recordings and/or programmed alerts and transmission for monitoring the respiratory system. The code can be used every 30 days by one practitioner only when at least 16 days of data have been collected on at least one medical device. The average national payment rate for CPT code 98976 is $49.
98977
Code 98977 reimburses musculoskeletal devices supplied with daily scheduled recordings and/or programmed alerts and transmission for monitoring the musculoskeletal system. This can be billed one time by one practitioner only when at least 16 days of data have been collected on at least one medical device. The average national payment rate for CPT code 98977 is $49.
98980
CPT 98980 bills for the initial 20 minutes of treatment time per calendar month. Time must include at least one interactive communication via phone or video with the patient during the month.
New in 2023, CPT 98980 can be billed “incident to” or under general supervision, which includes physicians, nurse practitioners (NPs), and physician assistants (PA). CPT 99457 is billed monthly. The average national payment rate for CPT 98980 is $48.
Notably, billing is not generally part of the Medicare benefit for qualified healthcare practitioners: physical therapists (PTs), occupational therapists (OTs), and speech-language pathologists (SLPs). Second, RTM services must be personally furnished by the billing qualified health care practitioner. When the practitioner is a PT or OT, a therapy assistant is required to be under the supervision of the OT or PT.
CPT 98981
In 2023 CPT 98981 covers each additional 20 minutes of treatment time per calendar month. This code has the same requirements as CPT 98980. The average national payment rate for CPT 98981 is $39.
What are the Differences in RTM vs. RPM?
Remote patient monitoring (RPM), or remote patient management or physiological monitoring, is not the same as remote therapeutic monitoring. As previously mentioned, RPM vs. RTM differs because RTM focuses on non-physiological monitoring. On the other hand, RPM focuses on physiological data. Providers can choose from a growing list of FDA-cleared remote patient monitoring devices and software services.
Remote patient monitoring enables the monitoring of patient vital signs outside of conventional clinical settings, such as at home or in remote areas. This telehealth service allows patients to take measurements from their homes. Once the measurement is taken, the data is sent in real-time to providers to measure physiologic data such as heart rate, weight, oxygen saturation, pulse rate, glucose levels, and more.
Over recent years, CMS created RPM billing codes for reimbursement for digital health, which has expanded Medicare reimbursement for remote patient monitoring. This is a separate category from RTM services. These 5 remote patient monitoring CPT codes are 99453, 99454, 99457, 99458, and 99091.
RTM vs. RPM Billing: 2023 RPM Key Takeaways
What are the key takeaways for medical professionals when it comes to RTM vs. RPM billing for 2023? Although future modifications to remote patient monitoring CPT codes are expected, CMS did not add the Proposed Rule RPM G codes to the final rule. CMS further establishes rates and provides yearly guidance on requirements and utilization for remote monitoring services.
As a result, these are the 3 key takeaways for RPM in 2023:
- No new RPM CPT codes appear in the final rule for 2023.
- Medicare non-facility reimbursement rates were updated for 2023
- RPM providers will continue to use CPT codes 99453, 99454, 99457, 99458, and 99091.
RTM vs. RPM: RPM 2023 CPT Code Reimbursement Rates
As of 2020, CMS adopted RPM CPT codes to pay for device setup, collection, interpretation, and processing of remote physiological data. This section explains exactly what the 5 RPM CPT codes cover in 2023, including the average reimbursement rate and requirements. These rounded numbers are based on non-facility national averages and vary by region.
99453
This code pays for device set-up and patient education on the use of equipment for vital sign monitoring such as blood pressure, pulse oximetry, blood glucose, respiratory flow rate, and weight. This one-time code is billed after the initial 16 days of monitoring. The average national payment rate for CPT 99453 is $19.
99454
Supplying the device for daily recording or programmed alert transmissions is billed under code 99454. It may be used more than once, given that the patient uses the device at least 16 days per month. CPT 99454 can be billed every 30 days. The average national payment rate for CPT 99454 is $49.
99457
This payment is for the initial 20 minutes of treatment management. An unspecified portion of that 20 minutes must involve interactive remote communication with the patient. Though, it is not explicitly defined how interactions must be provided. However, we assume that a video call, phone call, email, and text messaging would suffice. The average national payment rate for CPT 99457 is $48.
Moreover, CPT 99457 is billed “incident to” under general supervision. This means that Medicare providers can contract third-party remote patient monitoring companies to assist with RPM services. Ultimately, healthcare organizations can manage more patients and generate more revenue without significantly impacting workflows.
99458
In 2023, CPT 99458 encompasses each additional 20 minutes of RPM services, with a maximum of 60 minutes in a calendar month. Similar to CPT 99457, documentation of how the time is distributed is required. The average national payment rate for CPT 99458 is $39.
99091
CPT 99091 was new in 2022 but had more requirements than the preceding codes. In 2023, it covers a minimum of 30 minutes in a calendar month for the time it takes clinical staff to gather, interpret, and process data that a patient transmits. It also covers at least one communication, which occurs by phone or email, whereby medical management or monitor advising occurs. The average national payment rate for CPT 99091 is $53.
