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.
One Provider to Bill RPM or RTM Only One Time Per Patient
Rheumatology CPT codes 98977, 98980 and 98981 for RTM can be billed by only one provider in a 30-day period only one time per patient (episode of care, not a calendar month). However, other services, such as chronic care management (CCM), transition care management (TCM), principal care management (PCM) and chronic pain management (CPM), can be billed concurrently with either RPM or RTM.
General Information
RPM and RTM treatment management codes were created to report services that are provided when clinical staff utilize the results of remote monitoring devices to manage a patient under a specific treatment plan. These services are a general telehealth option classified under E/M services to collect and analyze patient vitals on an ongoing basis between regular office visits and can be furnished only by a physician, other qualified healthcare professional or clinical staff under the general supervision of a physician eligible to bill for Medicare E/M services. These services are part of a monthly billable program and track patients’ health issues/status. They must:
- Be for an established patient, one with whom the physician has had a prior new patient E/M service (which may have been done via telehealth); and
- Allow for both chronic and acute conditions.
Review the full overview of the RPM and RTM definition here.
RPM and RTM service updates are ongoing, so it is imperative that rheumatology practices remain up to date on all coding guidelines to ensure proper reimbursement. For questions and additional coding guidance for these services, contact the ACR Practice Management Department at [email protected].
