The Centers for Medicare & Medicaid Services (CMS) updated recent regulations to clarify some points about remote physiologic monitoring (RPM) and remote therapeutic monitoring (RTM) services for key areas, including the 16 days of data collection, established patients, global periods for surgery, and billing of RPM and RTM by only one practitioner only one time per patient. Below is an overview of the updates rheumatology providers and their staff should be aware of when billing for RPM or RTM services.
16 Days of Data Collection
The rule reestablished that data should be collected for at least 16 days in a 30-day period for remote monitoring services and applicable to existing RPM and RTM code families for the 2024 calendar year. In the 2024 Physician Fee Schedule (PFS) Final Rule, the CMS notes that “in the CY 2024 PFS proposed rule, we inadvertently listed all the RTM codes (88 FR 53204) in our discussion of these services and had made a general statement about the applicability of the 16-day data collection requirement. We would like to offer clarification that the 16-day data collection requirement does not apply to CPT codes 99457, 99458, 98980 and 98981. These CPT codes are treatment management codes that account for time spent in a calendar month and do not require 16 days of data collection in a 30-day period.”
Established Patients
As of May 2023, RPM services are limited to “established patients,” a requirement that is still in effect. In the coding guidelines, RPM services require an established patient relationship before the RPM codes can be billed for reimbursement, but RTM codes do not require the same guidelines based on the CMS ruling. As confirmed in the 2024 Final Rule, “RPM, not RTM, services require an established patient relationship after the end of the public health emergency (PHE).”
Note: An established patient is defined as any individual who has received any professional services, evaluation and management (E/M) service or other face-to-face service (e.g., surgical procedure) from this provider or another provider in the same specialty and same group practice within the previous three years.
Global Period for Surgery
Providers who do not receive payment for global services can offer RPM or RTM services during the global periods for surgery. If applicable, providers are allowed to provide RPM and RTM services separately if they are unrelated to the diagnosis of the surgical procedure with a global period.
