The Centers for Medicare & Medicaid Services (CMS) has issued its 2022 Medicare Physician Fee Schedule proposed rule. This time new CPT codes has been added for remote therapeutic monitoring (RTM), which will be totally new for medical coders.
Proposed Remote Therapeutic Monitoring Coding and Coverage and Coding
The remote therapeutic monitoring codes are described as follows:
- CPT code 989X1 — 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 989X2 — 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 989X3 — 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 989X4 — 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 989X5 — 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 (List separately in addition to code for primary procedure)
Of these, CPT 989X1, CPT 989X2, and CPT 989X3 are considered practice expense-only codes while CPT 989X4 and CPT 989X5 are professional work codes.
Key points on Remote Therapeutic Monitoring
Here are seven of the most significant takeaways about RTM from the 2022 proposed rule.
- CMS is proposing to apply the RVS Update Committee (RUC) recommended work RVU of 0.62 for CPT 989X4 and the RUC-recommended work RVU of 0.61 for its add-on code, CPT 989X5, as a means of maintaining parity with the two remote patient monitoring (RPM) treatment management codes (CPT 99457 and CPT 99458) upon which the two RTM codes are based.
- CMS is proposing the RUC-recommended direct practice expense (PE) inputs for CPT 989X4 and CPT 989X5 — the two treatment management codes — without refinement.
- CMS is proposing to refine the direct PE inputs for the three PE-only codes (CPT 989X1, CPT 989X2, and CPT 989X3).
- CMS is proposing to value the PE for CPT code 989X1 by crosswalking to the PE RVU for remote patient monitoring CPT code 99453 upon which the RTM CPT code was based.
- CMS is proposing to value the PE for CPT 989X2 and CPT 989X3 by crosswalking to the PE RVU for comparable RPM CPT code 99454, a code that includes payment for the medical device used to collect and transmit data. CMS notes that the only input to CPT 989X2 is a monthly fee of $25, which would not be paid as a direct cost under the Physician Fee Schedule.
- CMS is seeking comment on the typical type of devices and associated costs of those devices that might be used to collect the various kinds of data included in the code descriptors (e.g., respiratory system status, musculoskeletal status, medication adherence, pain) for the RTM services.
- Due to how the RTM codes are constructed, practitioners who are not physicians or non-physician providers (e.g., physical therapists) would not presently be able to bill the RTM codes. CMS is seeking comment on how to remedy the issues related to the RTM code construction to permit such billing.
Reference:
https://blog.prevounce.com/remote-therapeutic-monitoring-debuts-in-cms-2022-proposed-rule