So what is Remote Therapeutic Monitoring?

Over all, the remote therapeutic management codes are designed as direct mirrors of the remote patient monitoring CPT codes, with RTM intended for the management of patients utilizing medical devices collecting non-physiological data. Despite the planned CMS coverage of remote therapeutic monitoring as outlined in the proposed rule, it’s important to note that RTM is a concept where the specific requirements are still generally undefined. We have the CPT descriptions from the American Medical Association (provided above) and now what we’d describe as fairly vague, non-canonical descriptors by CMS in the proposed rule comments. We expect more information on these RTM codes in the coming weeks and will be sharing what we learn as details become clearer, but here’s a quick summary of what CMS seems to be proposing concerning RTM.

How Remote Therapeutic Management and Remote Patient Monitoring Are Different

CMS describes two major differences between RPM and RTM.

First is that providers that can’t bill for RPM may be able to bill for RTM. In the proposed rule, Medicare points out that the way the AMA designated the RTM codes as non-evaluation and management (E/M) does not allow Medicare to designate them as general supervision care management codes, hence the reason they’re looking for comments about ways to “remedy” this disconnect.

Second concerns the nature of the data collected, more specifically therapeutic for RTM versus physiological for RPM. RTM can be used for non-physiological medical devices like those used to support medical adherence (e.g., smart pill reminder systems) and medication symptom/adverse reaction applications. Essentially, any information that a medical device — including software that fits the definition of a medical device — can collect that is not physiological can be collected and billed for under RTM.

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Remote Therapeutic Monitoring