Only a very small percentage of clinics are offering remote therapeutic monitoring (RTM) services after almost two years of the services being permitted. Statistically, RTM CPT codes billed by outpatient therapists make up less than 0.03% of all qualified billing being submitted. What is taking so long for this line of service to reach main street? I believe the simple answer is math!
Therapists view calculations as kryptonite. We respect it, but then, avoid it at all costs. Let’s first review what is being discussed:
Estimated Reimbursement Amounts
The reality is RTM services are related to traditional therapy but contain a structurally different concept from what we are accustomed to. The widely familiar time-based codes that we are all familiar with (15 minutes) in the 97000 series (and subsequent billing of 8-minute or payor specific guidelines) are just fundamentally different from these 5 RTM CPT codes that we now have access to use.
As previously mentioned, almost two years have gone by (since January 2022), and the 98975, 98976, 98977, 98980, 98981 codes are all covered by Medicare and possibly by other commercial payors too. The most important concept to remember is that the purpose of these codes is to ensure that the patient is receiving on-going monitoring and not just a one-time service like therapists are accustomed to. It’s almost better to think of these codes as an on-going home exercise program that requires time, patience, and limited math skills.
Definitions for these codes are readily available online, so we can skip to the important details:
CPT 98975 is the initial set-up code for RTM services. This code is reportable only once per episode of care, only after 16 days of monitoring occurs and, in my opinion, should coincide with an evaluation. The reason I make this recommendation is because you need to document the device being used (activated), the education you provided to the patient (or family member/caregiver) and any physical device set-up required. This really is no different to what therapists have been doing forever, but just in another context: setting up a comprehensive home exercise program.
CPT 98976 is the monitoring of a patient’s respiratory system that most outpatient therapists are not performing or going to perform, so we will jump over the details for this code. Basic information, however, is that this code also requires 16 days of monitoring over a 30-day period before being allowed to bill and one would need to document the device and description of monitoring.
CPT 98977 is your “Wednesday”. Important, valuable, but exhausting. This musculoskeletal system status and monitoring code requires 16 days of monitoring and needs to take place over (within) a 30-day period. This is where math and time management will come into play since you only get the opportunity to bill this code when a certain number of days (16) are monitored in a 30-day window. The reason why this rule is in place, is because the spirit of the code requires on-going monitoring and not simply a one-time service. Supporting documentation would need to include the times and dates when monitoring occurred (the device used to capture this monitoring should also be recorded).
CPT 98980 is my favorite code because it resembles our familiar time-based 15-minute codes as well as the documentation requirements. This is also an “all-or-none” code and requires at least 20 minutes of interactive communication with a patient during a calendar month. One should document the time and date when this skilled service was performed (could be split into multiple times or days). Your clinical judgement and rationale for skilled therapy should be captured in response to the skilled service and data collected from the device. Don’t forget to clearly describe this information just like we do for functional outcome reporting (interpret the numbers).
The subsequent 98981 is identical to 98980 except that this code covers the additional 20 minutes during the same time period. So, if you provided 40 minutes of interactive communication during a calendar month for RTM skilled service, you may bill 1 unit of 98980 and 1 unit of 98981 and would typically submit them on the same date.
Basic Breakdown for An Episode of Care:
98975 can be billed after 16 days.
98976 can be billed after 16 days within a 30-day window.
98977 can be billed after 16 days within a 30-day window.
98980 can be billed once per month (First 20 minutes).
98981 can be billed for every additional 20 minutes per month.
For those of you who are old enough to remember drawing stick figures, printing out forms, copying index cards or similar hieroglyphics; that was essentially the origin of “remote” exercise programs. Apps and on-line home programs have evolved and with this progress, your RTM program should adapt and fill the technology void. How frustrating is it to continue to miss billing opportunities for your valuable time that you are already providing services? As therapists, we constantly discuss and educate patients, but then skip the billing component for the creation and set-up of these critical supplements that enhance a comprehensive therapy program. At the time of this blog, supervision leniencies are likely to be extended and approved in the foreseeable future, so licensed assistants can also continue to work within the therapy team environment for RTM services.
Bottom Line: Strategies to offer RTM services in-house or through an outsourced vendor need to match the culture and workflow of your business. Either way, everyone should be participating and offering RTM to patients if you believe that technology is a part of the future of outpatient therapy.