Remote Therapeutic Monitoring: New CPT Codes and What They Mean

The Centers for Medicare and Medicaid Services released their proposed 2022 Medicare Physician Fee Schedule (MPFS) on July 13th. Included were five new CPT Remote Therapeutic Monitoring (RTM) codes covering non-physiologic patient data—such as respiratory system status, musculoskeletal system status, therapy/medication response, therapy/medication adherence, and pain. While the addition of RTM codes is a positive development for virtual care advocates, the proposed MPFS raises important questions.

Understanding Remote Therapeutic Monitoring Codes

The new RTM codes closely resemble Remote Physiologic Monitoring (RPM) codes introduced earlier. Similarities include service codes, device codes, education on equipment usage, and a setup code. Here's a summary from the Proposed Rule:

• CPT Code 989x4: First 20 minutes of RTM treatment management by a qualified healthcare provider with one interactive communication per calendar month.
• CPT Code 989x5: Each additional 20 minutes (reported separately alongside 989x4).
• CPT Code 989x1: Initial education and setup for remote therapeutic monitoring (musculoskeletal, respiratory, adherence, and therapy response).
• CPT Code 989x2: Monitoring respiratory system via device data, alerts, or recordings over 30 days.
• CPT Code 989x3: Monitoring musculoskeletal system similarly over 30 days.

Key Differences Between RTM and RPM

RTM Covers Non-Physiologic Data

While RPM focuses on physiologic data, RTM covers non-physiologic metrics like pain levels and medication adherence. CMS hasn’t strictly defined “non-physiologic,” but implies it includes patient-reported outcomes related to therapy response and symptom tracking.

RTM Embraces Self-Reported Data

Unlike RPM, which mandates device-based automatic data transmission, RTM allows for self-reported metrics via platforms categorized as Software as a Medical Device (SaMD). This is important for tracking pain and adherence data.

Payment Parity With RPM

CMS proposes payment parity between RTM codes (989x4, 989x5) and RPM codes (99457, 99458). This ensures fair compensation for therapists and other healthcare professionals.

Expanded Provider Eligibility

RTM is designed to allow a broader group of providers—including physical therapists, occupational therapists, and potentially speech-language pathologists—to bill for services that weren’t previously reimbursable under RPM.

Unanswered Questions About RTM

Is RTM an “Incident to” Service?

There is ambiguity regarding whether RTM can be billed “incident to” a supervising physician. Unlike RPM, RTM codes lack descriptors for clinical staff time, complicating billing protocols for allied health professionals.

Is RTM a Care Management Service?

CMS clarifies that RTM is not a care management service. Unlike RPM—which resembles E/M services—RTM codes are medicine-based and designed for treatment monitoring rather than care coordination.

Can a QHCP Bill for RTM?

Yes, physical therapists and other qualified healthcare professionals (QHCPs) are eligible to bill RTM, although CMS continues to seek clarification on which providers and billing structures are appropriate.

For more information on the proposed CPT codes or to get started with an RPM program tailored to your clinic, schedule a meeting or explore accuRPM—our Remote Patient Monitoring solution designed for modern healthcare