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Remote Therapeutic Monitoring (RTM) FAQs

What is Remote Therapeutic Monitoring?

Remote Therapeutic Monitoring (“RTM”) uses digital technologies to gather non-physiologic data from patients in one location (e.g., their home) and transmit that information to healthcare providers in another location (e.g., their doctor’s office) for analysis. RTM devices collect various forms of health data, including respiratory system status, musculoskeletal system status, therapy/medication adherence, and therapy/medication response to monitor patients’ respiratory or musculoskeletal systems. Providers can use this data to monitor patients’ health conditions, provide recommendations, track medication adherence and pain levels, and/or make changes to patients’ plans of care.

What benefits does RTM provide to patients, providers and healthcare organizations? 

RTM expands the types of practitioners who can furnish and bill monitoring services and helps patients by allowing them to self-report key pieces of information that their care teams can use to correlate between therapeutics used and treatment efficacy. This can lead to faster, more personalized, and more effective treatments, improving patients’ quality of life and decreasing their healthcare costs. RTM can help providers and health care facilities reduce the number of hospitalizations, readmission rates, and patients’ length of stay by identifying adverse health events sooner. All of these factors can help reduce the overall cost of care.

What are the RTM codes? 

CPT code 98975 ($18):

Remote therapeutic monitoring (e.g., respiratory system status, musculoskeletal system status, therapy adherence, therapy response); initial set-up and patient education on use of equipment

CPT code 98976 ($54):

Remote therapeutic monitoring (e.g., respiratory system status, musculoskeletal system status, therapy adherence, therapy response); device(s) supply with scheduled (e.g., daily) recording(s) and/or programmed alert(s) transmission to monitor respiratory system, each 30 days

CPT code 98977 ($54):

Remote therapeutic monitoring (e.g., respiratory system status, musculoskeletal system status, therapy adherence, therapy response); device(s) supply with scheduled(e.g., daily) recording(s) and/or programmed alert(s) transmission to monitor musculoskeletal system, each 30 days

CPT code 98980 ($48):

Remote therapeutic monitoring treatment management services, physician/ other qualified health care professional time in a calendar month requiring at least one interactive communication with the patient/caregiver during the calendar month; first 20 minutes

CPT code 98981 (*$39):

Remote therapeutic monitoring treatment management services, physician/other qualified health care professional time in a calendar month requiring at least one interactive communication with the patient/caregiver during the calendar month; each additional 20 minutes)

*Please Note: Reimbursement amounts listed represent a national average; exact reimbursement amounts vary by geographic region. Amounts are based on CMS 2022 non-facility pay rate and are subject to change.

Is RTM intended to be used for non-physiologic data? 

Yes.  In the 2022 Rule, CMS gives examples of health conditions where non-physiologic data can be collected, including musculoskeletal system status, respiratory system status, therapy (for example, exercise and medication) adherence, and therapy response. Providers should use their professional judgment in determining what constitutes “non-physiologic” or “therapeutic” for purposes of RTM.

Who can bill Medicare directly for RTM services? 

Providers who are eligible to bill Medicare directly for their services and whose scope of practice includes RTM services are eligible to bill for RTM services. This may include:

  • Physicians
  • Anesthesiology Assistants
  • Certified Nurse Midwives
  • Certified Registered Nurse Anesthetists
  • Clinical Nurse Specialists,
  • Clinical Social Workers
  • Nurse Practitioners
  • Occupational Therapists in Private Practice
  • Physical Therapists in Private Practice
  • Physician Assistants
  • Psychologists
  • Qualified Audiologists
  • Speech Language Pathologists in Private Practice
  • Registered Dietitians or Nutrition Professionals

What types of devices can be used for providing RTM services?

CPT codes 98976 and 98977, billed for the ongoing supply of RTM devices, provide reimbursement for devices that monitor the respiratory (98976) or musculoskeletal (98977) system. 

The CPT Manual states that each device used to collect RTM data must meet the definition of a “medical device” as that term is defined by the U.S. Food and Drug Administration (“FDA”) in the Food, Drug & Cosmetics Act (“FD&C Act”). This does NOT mean that a device used must necessarily go through the FDA “clearance” or “approval” process for reimbursement purposes, but the FDA may require this depending on the device’s status under applicable FDA pathways. Importantly, the FDA’s definition of a “medical device” includes certain software functions. More information regarding medical devices under the FD&C Act can be found on the FDA website.

What is a Software as a Medical Device (SaMD)?

Software as a Medical Device, or SaMD, can be described as a class of medical software designed to carry out one or more medical functions without the need for actual hardware. This can comprise of software or applications intended to treat, diagnose, cure, mitigate or prevent disease. Some of the applications of SaMD platforms serve the following functions:

  • Screening and diagnosis
  • Monitoring and alerting
  • Chronic condition and disease management
  • Digital therapeutics

Qualifying as a Software as a Medical Device requires FDA Approval.

How can Force Therapeutics help with RTM?

Force’s digital care platform is uniquely positioned to track remote therapeutic activities and verify meaningful patient engagement and adherence to care plans. Our clinically validated solution satisfies the FDA requirements for software as a medical device (as defined in the FD&C Act) and is eligible to be used for patient monitoring. Force recently underwent a thorough audit of our platform and received legal and compliance approval to support systems with billing opportunities within remote therapeutic monitoring. 

Please note: The information in this document does not constitute legal advice to the reader, nor is it a guarantee of reimbursement for any claims.