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RTM Clarifications from CMS 2024 Medicare Physician Fee Schedule

In its 2024 Medicare Physician Fee Schedule (MPFS) final rule, the Centers for Medicare & Medicaid Services (CMS) included a section titled “Clarifications for Remote Monitoring Services”, responding to comments received on the proposed rule relating to remote patient monitoring (RPM), remote therapeutic monitoring (RTM), and digital therapeutics applications.

The following outlines key points from CMS clarifications relating to RTM in musculoskeletal (MSK) applications, as well as the responses that CMS offered for some RTM-related questions. What follows is exclusively for informational purposes.

RTM established patient requirement

CMS has clarified that RTM, unlike RPM, does not require an established patient relationship for the time being. That said, CMS did suggest that providers should only utilize RTM after setting a treatment plan, as follows:

“While we have not specified in rulemaking whether the RTM services require an established patient relationship, we believe that similar to RPM, such services would be furnished to a patient after a treatment plan had been established. Presumably, a billing practitioner would establish such a treatment plan after some initial interaction with the patient. We will work to clarify this policy further in future rulemaking.”

16/30-day requirement

CMS has previously maintained that the requirement to submit 16 days of data in a 30-day period for codes 98975 and 98977 was reinstated as of the end of the COVID-19 public health emergency. In its latest rulemaking, CMS noted that the text of its proposed rule “inadvertently listed all of the RTM codes in our discussion of these services and had made a general statement about the applicability of the 16-day data collection requirement”, clarifying that this requirement is not applicable for RTM treatment management codes 98980 and 98981, given that they account for provider time spent in a calendar month.

In effect, RTM codes 98975 and 98977, accounting for initial set-up and patient education on use of equipment and the device supply to monitor the MSK system, do require 16 days of data in a 30-day period, whereas 98980 and 98981, which are treatment management codes, do not.

RTM with other services

Having previously clarified that RTM cannot be billed in conjunction with RPM for the same patient, CMS has reiterated that RTM (or RPM) may however be used with Chronic Care Management (CCM), Transitional Care Management (TCM), Behavioral Health Integration (BHI), Principal Care Management (PCM), and Chronic Pain Management (CPM) services as long as no double billing occurs. In addition, CMS further clarified that only a single provider can bill for RTM (or RPM) for each patient in a 30-day period, regardless of the number of remote medical devices being used or the number of practitioners monitoring the patient.

RTM in the global period

CMS has provided clarification that billing practitioners receiving a global service payment are prohibited from furnishing RTM for the same condition for the same patient, but are permitted to furnish RTM for the same patient for a separate condition not linked to the global procedure or service.

Nonetheless, other practitioners who did not furnish the global procedure and therefore do not receive a global service payment are still permitted to provide RTM for that same patient even if it is for the same condition covered by the global service payment received by another practitioner, which CMS noted as follows:

“Providing RTM or RPM services during the global period is permitted if the practitioner is not receiving global service payment because they did not furnish the global procedure.”

RTM supervision and payment updates

CMS has changed its RTM supervision requirements to allow general supervision (rather than direct supervision) for therapy assistants of physical and occupational therapists (PTs/OTs) in private practices. In addition, CMS has finalized its proposal to allow Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs) to bill for RTM through general management HCPCS code G0511.

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