Remote Therapeutic Monitoring (RTM) Overview & Benefits

RTM codes broaden Medicare reimbursement for remote monitoring beyond the existing Remote Physiologic Monitoring (RPM) codes and represent one of the latest advancements to modernize reimbursement for codes are intended to expand the scope. The new codes are intended to expand the scope and reach of digital health technologies to reimburse monitoring of non-physiologic data.

CMS recognizes therapeutic data as an important category of patient information that can be assessed remotely. RTM is designed for the management of patients using devices that collect therapeutic, non-physiologic data. Data around indicators such as therapy/medication adherence, therapy/medication response, and pain level can be collected and billed under RTM codes. Non-physiologic measures can allow a provider to determine how well a patient is responding to a medication, what social or environmental factors affect the patient’s respiratory or musculoskeletal health status, and what changes could be made to improve the patient’s health. This differs from RPM codes, which only can be used in conjunction with tracking physiologic data (e.g. heart rate, blood pressure and blood sugar levels) - patient status vitals important to ongoing chronic care management. RTM can be used for non-physiologic medical devices like those used to support medical adherence (smart pill reminder systems) and medication symptom/adverse reaction applications.  Really any medical device that can collect data that is non-physiological can be collected and billed under RTM.

The intent for RTM is different in scope and data gathering methodology from RPM. The main differences between RPM and RTM are expansion beyond internal medicine providers and tracking non-physiologic versus physiological data. The codes are limited to the musculoskeletal system and respiratory system, and are intended to be non-physiologic in nature with attention to therapy, adherence and response. The expansion beyond internal medicine providers and the addition of specialty areas, shows that providers that currently can’t bill for RPM (depending on specialty area) may be able to bill for RTM.

Also, the clinical scope of what’s covered is fairly limited – clinical uses eligible for monitoring device reimbursement only are only for respiratory condition data transmissions or musculoskeletal condition data transmissions. Most stakeholders are optimistic that CMS will expand the list of clinical conditions in the future. In 2023, CMS expanded the RTM codes to include and allow for general supervision billing.  Prior to this expansion in 2023, RTM codes could not be designated as care management service – and a physician could not order and bill for RTM services while having remote-based, non-physician practitioners perform the work under general supervision. We anticipate further expansion of RTM in the coming years.

Finally, CMS allows self-reported/entered data for non-physiologic data RTM codes, but requires use of an FDA approved medical device, not a wellness device.  This is another significant difference from RPM code requirements, which also require the device to digitally (automatically) record and upload patient physiologic data – and specifically do not allow patient self-recorded, reported or manually entered data.

Key features of RTM, and how it differs from RPM:

- RTM is non-physiologic, therapeutic data
- RTM allows for respiratory and musculoskeletal data only
- RTM allows for both self-reported data as well as automated digital - uploads
- RTM is intended for nurses, physical therapists and overseeing specialty providers.  Intent was expansion to allow more practitioners previously unable to transmit and bill for RTM to be able to.

Since 2023, CMS has maintained the same codes, but expanded the scope of RTM codes to include and allow for general supervision billing, expanding the scope of application of RTM. This is an exciting and important development that now allows the full clinical staff team to utilize RTM more efficiently and effectively, while improving patient care. Providers can focus on direct patient care, and clinical staff can support patients using the tools provided. It is expected that the coding, scope, range and specificity of RTM coverage, provider specialty and services will continue to grow and change in the coming years as CMS further define and expands its RTM policies.

Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs) bill for CCM or PCM services performed by clinical staff under HSPCS G0511.  An RHC/FQHC can bill only one unit of G0511 per beneficiary per month, regardless of time spent on PCM or CCM for the patient.

Benefits of RTM

RTM allows physicians to gain more information on how a patient’s daily life is impacting their conditions and overall health.  This allows for the personalization of care plans to enable the best possible outcomes.  Monitoring patients in the ways described by RTM, provides opportunities for lowering spending on preventable hospitalizations, ED visits and urgent care too.

Medsien’s RTM program can help your patients and practices benefit from these growing trends in patient care by improving outcomes, patient engagement, patient satisfaction and increasing reimbursement. ‍

Improves:

- Health outcomes

- Patient engagement

- Patient satisfaction

- Reimbursement

Decreases:

- Costs

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For 2024, CMS provided a lot of clarifications to language and rules regarding RPM and RTM existing policies and codes, but no new codes. They clarified that you can bill remote monitoring RPM or RTM with other patient care management services - but not both RPM and RTM; that 16-days of monitoring is not requirement for RPM or RTM programs; that only one practitioner can bill Medicare RPM or RTM device data collection services; that you can not bill for RPM or RTM if receiving global surgery payments; and that RTM technically does not contain an established patient requirement, but Medsien will continue to proceed as if it does to ensure accuracy and rigorous compliance. New for 2024 - FQHCs and RHSCs can bill Medicare for RPM and RTM. Also new for RTM only,  PTs and OTs can bill RTM for assistants under the general supervision outside of private practice. The 2024 Final rule reflects a continued fine tuning of RPM and RTM Medicare billing guidance.  See the CMS 2024 update to learn more.

To learn more about Medsien RTM services visit Remote Therapeutic Monitoring.

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Updated 1/1/24