No matter what subject you’re talking about, whether it’s interior design or the best way to prepare a steak, there is no such thing as a universal opinion. Part of this phenomena is due to a lack of universal knowledge. Someone who doesn’t know how to cook or season sauerbraten, red cabbage, and bread dumplings might think that it’s a terrible meal when in reality, they haven’t tried the cooking method or spice combination that could make this German dish sing. But even when everyone has the same knowledge and understanding of a topic, you’ll still find different opinions abound. Not everyone likes the Austrian style of sauerbraten!
All that said, I think I’ve encountered an opinion so widely held that it’s nearly universal: billing for physical therapy treatment is frustrating, cumbersome, and overly complicated. People may disagree over which aspects of billing are the worst to handle, but overall, I’ve found that most PTs (and even the majority of PT billers) agree with this statement.
PTs bond over billing gripes—but it could be clouding our vision.
On the surface, bonding over shared gripes may seem like a decent way to build bridges and coalitions, but I suspect that our propensity to instantly “boo” strict compliance regulations and ever-changing billing rules is preventing us from working with some of our billing tools.
Take the recently created remote therapeutic monitoring (RTM) codes that CMS finalized in the 2022 final rule. I think far too many PTs dismissed these codes as unimportant or at least far less important than some of the other changes that rolled out. But the reality is that PTs were handed an opportunity on a silver platter and I think it’s in our best interest as physical therapists to reach out and take it. Allow me to outline the opportunity as I see it.
What are RTM codes?
Remote therapeutic monitoring (RTM) codes describe treatment scenarios where PTs, OTs, or SLPs can remotely monitor health conditions via a connected medical device, including “musculoskeletal system status, respiratory system status, therapy (medication) adherence, and therapy (medication) response.” Unlike with their sister remote patient monitoring (RPM) codes, RTM codes allow patients to self-report their data in addition to allowing the device to automatically upload the information to a medical records system.
Why can PTs suddenly use RTM codes?
Why did RTM rules change so suddenly? It boils down to this: CMS identified a problem while writing the 2021 final rule. In 2021, there were no RTM codes, and therapists were billing remote monitoring scenarios (like the ones outlined below) using RPM codes. However, RPM codes are evaluation and management (E/M) codes, and rehab therapists are not technically allowed to bill them.
CMS recognized the benefits of allowing PTs to furnish RPM, so it created therapy-specific sister codes: RTM codes. It was a rare case of CMS creating a tool to address a problem ahead of the curve.
What are the benefits of RTM codes—and why should therapists use them?
Remote monitoring can offer therapists a ton of great information that can help them better guide their patients’ care. Think about it, A plan of care is always limited by the amount (or quality) of information that a patient (or their caretaker) supplies. But with remote monitoring devices, PTs can get accurate information about how the patient responds to different situations in more functional and ADL activities outside of the clinic. This also provides another avenue in collecting patient reported outcomes. We still have not gotten to a place where PROMs are a routine part of our data collection; however, RTM gives therapists another mechanism of data collection (one they get paid for) and provides the patient an opportunity to actively engage in understanding their progress
Imagine these scenarios.
Imagine this: A therapist sends home a POTS patient with a device that monitors blood pressure and heart rate and asks the patient to use the device (or input data themselves) while performing specific ADLs and HEP exercises. RTM codes can be used for collecting patient reported outcomes along with logging their daily compliance with completion of their HEP. By doing this, the therapist has empowered the patient to actively participate in their own care; the patient can learn about the limits of their body while providing the PT with information that will help them craft a plan of care that touches on important ADLs without exceeding the limits of the patient’s body.
Or consider this situation, as posed by an article from Foley & Lardner LLP: A practitioner sends home an asthmatic patient with a “medical device that monitors when the patient uses the inhaler, how many times during the day the patient uses the inhaler, how many puffs/doses the patient uses each time, and the pollen count and environmental factors that exist in the patient’s location at that time.” Think of how invaluable this information could be to an outpatient respiratory therapist who’s trying to help the patient improve their respiratory strength without knowing the ins and outs of the patient’s home environment.
RTM codes could even help therapists provide better virtual care, giving PTs data that they wouldn’t normally have for a patient who’s not at the clinic.
RTM codes enable therapists to improve their care.
Because RTM codes are so new, there isn’t a lot of data about the extent to which they improve patient care. However, RPM codes (the ones rehab therapists can’t bill) have been around for far longer, and several studies suggest that remote monitoring:
- Increases patient engagement and satisfaction,
- Increases revenue by virtue of supporting virtual care,
- Reduces emergency visits and hospital readmissions (in acute care settings), and
- Improves patient pain management, therefore reducing overall pain.
These benefits could make a world of difference to patients especially to those who struggle to leave their home because of mobility issues, a lack of transportation, or other health concerns. But that’s not all.
We could use the data collected through RTM devices to advocate for physical therapy as a mode of care.
PT advocates are simultaneously helming or supporting a large number of advocacy movements. Not only are people pushing for the adoption of the PT compact, we’re also pushing for Medicare reform, improved workforce diversity, better insurance payments, and even lower physical therapy copays, to name only a few causes.
The one thing that all of these movements universally need is data. If we want to get CMS, state governments, and commercial payers on our side, then we need to prove to them that we check all the boxes. We need to prove that physical therapy is an affordable, effective, and underused tool that can help patients live without pain while simultaneously reducing costs for payers. With RTM, we have the ability to collect more actionable data and measurably prove how we help patients in their home environments. We could use this data to then show that we are capable of managing a greater portion of a patient’s care, thus pulling the PT to the forefront of the care continuum.
We have an opportunity and we should use it.
All too often, physical therapists have to fight tooth and nail for any beneficial regulatory changes. This time, the beneficial changes fell right into our laps. We would be remiss to not take advantage of an opportunity like this especially given how it can directly benefit patients. There’s no reason to hesitate, we know that some therapists are already getting paid for RTM codes.
How should therapists bill RTM codes?
To be clear, I’m not suggesting that PTs bill these codes without rhyme or reason. It’s critical that we only administer RTM if we believe that it will benefit the patient and we adhere to all compliance and billing standards. But these codes are fairly flexible; I suspect that many therapists could find ways to employ them in their practices. Here are some of the nitty gritty details.
The RTM CPT codes are as follows:
- 98975: 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
- 98976: 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
- 98977: 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
- 98980: 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
- 98981: 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)
The Centers for Medicare and Medicaid Services (CMS) hasn’t specified any example devices that rehab therapists can use to bill these codes, simply stating that the device must be defined a “medical device” by the FDA. This is where CMS pointed therapists to Section 201(h) of the Food, Drug, and Cosmetic Act, which essentially says that medical devices must be:
- “Recognized in the official National Formulary, or the United States Pharmacopoeia, or any supplement to them”;
- Intended to diagnose or help cure, mitigate, treat, or prevent diseases or other conditions;
- Intended to affect the body without (or nearly without) chemical action; and
- does not rely on metabolization.
(Though of course I urge you to refer to the official wording from that law and not my paraphrasing.)
What if we don’t use these codes?
CMS has indicated that it’s not totally happy with the current structure of the RTM codes and I believe there’s a very good chance that we’ll see some changes to these codes in the final rules to come. That said, I don’t think that this is a “use it or lose it” type of situation. CMS knows that these services are important to beneficiaries, so it doesn’t want to remove them.
But if we don’t use all of the tools that we have to collect data and inform our advocacy efforts, then I think we’re still losing, a little bit. We’re losing out on the opportunity to advance the PT profession. We’re losing the chance to provide the best possible care to our patients. We’re losing an opportunity to combat the 90% problem.
I’m sure at this point, a number of you readers disagree with my call to action (there is no universal opinion, after all!). But I hope that we can agree on something else: The PT profession faces some big challenges, and we need to use measurable data to support our advocacy efforts and empower PTs to achieve greatness in practice.