FAQ: Embracing Digital Health: Why Rehab Therapists and RTM are a Match

Introduction

Every new relationship comes with no shortage of questions, as evidenced by the number of rehab therapists looking to get to know remote therapeutic monitoring (RTM) a little better during our most recent webinar. And while our expert panel tackled as many as they could during the Q&A session, there’s inevitably always more questions than time permits. That’s why we package them up and deliver answers like a dozen roses to your front door—with the aid of some of our RTM experts. 

Remote Therapeutic Monitoring Use Cases

Do neurological diagnosis codes qualify for RTM? Is there a standard definition of what defines a musculoskeletal diagnosis and a neurological diagnosis? Are diagnosis codes for unsteadiness and dizziness considered musculoskeletal (MSK) for 98977? 

This subject was touched on briefly by WebPT VP of Outcomes and Clinical Transformation Susan Lofton, MPT during the webinar, but merits revisiting. While specific diagnoses pertaining to a neurological impairment (e.g., multiple sclerosis or Parkinson's Disease) would not fall under the MSK umbrella, there are impairments associated with neurological diseases that can be musculoskeletal in nature—like diagnosis codes R26.81 (unsteadiness on feet) and R42 (dizziness). So, if the treating therapist feels there are MSK impairments that a rehab therapy POC could address, and RTM is of benefit to this patient, then defensible documentation would warrant use of RTM for these codes.

Can RTM be used for patients on a maintenance plan of care due to chronic conditions like Parkinson's disease or multiple sclerosis?

This question is similar to the one above. Often maintenance plans of care—the kind deemed reasonable and necessary by CMS—are addressing MSK impairments. So, regardless of the chronic condition, if your documentation shows MSK impairments, then RTM may be of value to your patient.

Are speech therapists also allowed to bill RTM codes?

Yes! According to the American Speech-Language-Hearing Association, speech language pathologists can use the full range of RTM codes, including the recently introduced 98978.   

Do we have to be a Durable Medical Equipment (DME) provider in order to bill for the RTM device?

No, RTM is available for all rehab therapists regardless of their status as DME providers.

How has RTM been used in pediatrics?

Many pediatric cases have MSK impairments that are either primary or concomitant with the referred diagnosis. Using RTM for those documented MSK impairments would inevitably lead to improved outcomes for the patients and their caregivers. 

Can RTM codes be billed for prosthetic usage monitoring and occupational therapy after upper limb amputation?

According to Keet’s Clinical Content Product Manager, Kathleen Rosas, using RTM with prosthetics would depend upon whether the provider feels it falls under the definition of a MSK or respiratory diagnosis, since certain diagnoses don't count towards RTM. It also depends on whether the provider is actually using an RTM app and the data provided from that app; some prosthetics companies provide apps for smart limbs, which wouldn’t qualify under RTM. 

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Billing for Remote Therapeutic Monitoring 

Regarding 98980, when does the 30-day window start? Is it upon first use of the device or upon providing the device and educating the patient on use?

Tip of the hat to Rick Gawenda, who answered this question in the chat before we could even get to it: “Per the American Medical Association, CPT Changes 2022: An Insider’s View, an episode of care is defined as ‘beginning when the remote therapeutic monitoring service is initiated and ends with attainment of targeted treatment goals.’”

Is there a fee reduction if PTAs or OTAs monitor the patient and/or have virtual patient interaction?  

As per Lofton, the de minimis standard will apply to CPT code 98975 (set up), 98980 (monitoring requiring at least one interactive communication for first 20 minutes), and 98981 (monitoring for subsequent 20 minute intervals) if provided in whole or in part by a PTA or an OTA. However,  the de minimis standard will not apply to CPT codes 98976 (supply of device for respiratory conditions), 98977 (supply of device for MSK conditions), and 98978 (supply of device for cognitive behavioral therapy).

If a therapist bills RTM codes for a Medicare patient in conjunction with a daily treatment, can those codes count towards other services billed that day? Can any time spent going over RTM with the patient during their regular scheduled session be put towards billing codes 98980 and 98981?

According to Lofton, you cannot count any billable time towards 98980 or 98981 that is being applied towards other services billed on that same day. The minutes either need to go towards the RTM codes or towards the therapy treatment CPT codes. 

How many communications sessions are allowed per month? And can these all be billed under 98981?

There’s no limit to the number of communication sessions per month. For billing purposes, you should bill 98980 for the first 20 minutes of monitoring activity, and 98981 for every subsequent 20 minutes of monitoring. We should again note that 98981 is subject to the de minimis standard, and can be billed every calendar month.  

Can RTM codes be billed for prosthetic usage monitoring and occupational therapy after upper limb amputation?

No, RTM needs to be furnished under a therapy plan of care. 

Can RTM codes be billed by therapists who practice in facility-based settings, such as hospital outpatient therapy departments or homecare?

Yes, RTM services are reimbursed by Medicare when therapy services are provided under an outpatient setting with an outpatient POC that is paid by the Medicare Physician Fee Schedule (MPFS). Therefore, RTM can be billed under hospital-based outpatient therapy, rehab agencies, Comprehensive Outpatient Rehab Facilities (CORFS) and similar entities. For homecare, therapy services must be provided under Medicare Part B to qualify for RTM code reimbursement. 

Does the 20% copayment apply for patients with RTM? Would patients be responsible for copays when they are not actually in office?

For added costs to the patient like copays or coinsurance, the best method for a direct answer is to call the specific representative for that particular insurance. However, for Medicare, the 20% coinsurance does apply, so patients will either pay this out of pocket or via supplemental insurance. 

Do RTM codes count towards the 10-visit progress note? What about allowable visits and visit authorizations?

For the purposes of Medicare and the 10-visit rule, the RTM codes do not count as a visit towards the next progress note, because RTM is not considered an “in-person visit” nor is it considered telehealth. In terms of specific authorizations, that will depend on the specific insurance carrier, so consulting with your insurance representative is recommended for the most accurate answer.

Would there ever be a time that PT could use the respiratory-based codes? Can you help explain what that would look like? 

At present, there is no particular template or guidance for physical therapists using respiratory code 98976. As was discussed in the webinar, proper coding and documentation to support the use of each code is paramount, followed by applicable use of the right code. For the most direct guidance in using the respiratory RTM code, consult your local MAC. If you are looking for more information, the AMA has provided this example of using the respiratory RTM codes as it pertains to their practice.

Can RTM codes be billed together? And if so or not are there any specific modifiers?

If you’re providing a patient with a RTM device or software (98977) and going through the initial setup and education (98975) as you start RTM with a patient, you would be able to bill those codes together, although we should note that 98975 is billed once per episode of care and 98977 is billed every 30 days. If you are using PTAs or OTAs for any of these activities, a CO or CQ modifier may be required.   

Scheduling Remote Therapeutic Monitoring Sessions

Is it suggested to piggyback an RTM visit on a regular scheduled visit? Or should you schedule a separate RTM visit on the last day of the month or the first day of the following month? 

Utilizing the RTM affords more flexibility in delivering quality care after the patient leaves face-to-face contact. With this flexibility comes more reliance on the provider to exercise sound clinical judgment on when best to schedule and perform RTM follow-ups and implementation. 

What are some best practices for the "virtual" contact with the patient/caregiver? 

Lofton emphasizes that, ultimately, therapists need to do what is clinically appropriate for helping their patients recover. She also notes that many therapists have not optimized their follow-up conversations with patients to this point because they were not previously reimbursed for their time. However, this has obviously changed with the onset of RTM. Providers can now contact patients by phone or through FaceTime to see if they have questions or offer suggestions on completing home exercises—and bill for it. All that said, it’s on the provider to use their clinical judgement to establish an appropriate protocol for virtual contact with patients/caregivers.

Can administrative support staff help with implementing CPT code 98975? As in, with helping a patient download the application. 

Downloading the application isn’t necessarily included with code 98975, and anything done beyond that would not be within the scope of support staff’s duties per Medicare compliance. Code 98975 is intended for providers setting up the device for patients, as well as any time spent educating the patient. 

Is there any issue with billing code 98975 after a normal evaluation (97161/97162/97163) is already performed? Or if the initial visit is billed as 98975, can we then bill a normal evaluation code for an in-person visit?

The RTM codes serve as a method to engage patients for improved adherence to rehab therapy as well as monitor how patients respond to rehab therapy. As of yet there is no clear guidance to the order by which 98975 should fall in relation to an initial evaluation, but would be best served as an adjunct to the in-person rehab therapy plan of care.

What components need to be documented in a note when billing RTM services? Is there an example of documentation that is required for each encounter with the patient on RTM?

For code 98975, providers need to document any HEP, PROMs, or educational materials assigned to a patient. Codes 98976 and 98977 require providers to document the name and description of the device provided to the patients. And both codes 98980 and 98981 stipulate that providers document the data collected from the RTM device or software, the time and date of interaction with a patient, and any changes or decisions made about treatment that are derived from the RTM data collected. 

Do you need to add goals for RTM on the plan of care (POC)?

At this time, RTM is meant to facilitate patient adherence to the POC and monitor their response to treatment. For this reason, a POC would not need to reflect goals related specifically to RTM.

If a patient reviews an HEP, answers a message, and reads an educational article on the same day, does this count as three separate interactions?

Providing the patient’s educational material falls under code 98975, which is only billed once per episode of care. Codes 98980 and 98981, which are the monitoring codes, are billed based on the time spent monitoring a patient rather than number of interactions. If a patient is reviewing a HEP and reading educational material, that wouldn’t fall within the scope of monitoring; however, if a therapist is spending at least 20 minutes responding to a patient’s message and reviewing their progress, that would be billable under 98980. 

There’s still much to unpack about RTM as it continues to evolve with new rules and greater adoption, but for now, rehab therapists can feel more confident in implementing RTM into their own practices to better treat patients and billing for those services. 

If you feel you may need some extra help monitoring and managing your clinic’s RTM services, give us a shout! We’d be happy to schedule a free consultation of our RTM Dashboard.