The PT, OT, and SLP’s Guide to Remote Therapeutic Monitoring

Introduction

The present healthcare landscape is nearing an inflection point where the traditional fee-for-service model is rendering private practice clinics unprofitable while simultaneously running up costs for insurers and their beneficiaries. To combat this, the era of value-based care (VBC) is becoming ever more imminent—and achieving optimal patient outcomes at a lower cost to the patient and payer is the primary directive.

A key component to improving the individual care, health, and cost of both individuals and populations (a.k.a. the triple aim of VBC) is the ability to extend MSK treatment beyond clinic walls—and bill for it. As such, remote therapeutic monitoring (RTM) codes were introduced to physical therapists (PTs), occupational therapists (OTs), and speech-language pathologists (SLPs) in 2022.

However, as with any new CPT code, there is a considerable learning curve clinicians must undergo before they feel comfortable incorporating them into their practice. With that in mind, we’ve created this guide to help you get up to speed on all things RTM, starting with the most fundamental question:

What is remote therapeutic monitoring? 

RTM is a method of monitoring and collecting non-physiological data from patients via an approved, connected medical device. As explained in the 2022 final rule, that data includes “musculoskeletal system status, respiratory system status, therapy (for example, medication) adherence, and therapy (for example, medication) response.” Patients are also able to self-report data within these connected medical devices and software, which is essential for rehab therapists looking to monitor patients’ pain levels, tolerance to therapy, and other related data during the plan of care. 

Is RTM the same as RPM?

Although similar in that remote patient monitoring (RPM) codes served as a template for RTM codes after CMS saw just how effective RPM was in providing treatment during the pandemic, RTM and RPM are not the same. In fact, there are a few key differences that determine who can use these codes and when. These include:

• The difference in the data that is being collected;
• The difference in how the data is being collected; and
• The difference in which clinicians can bill for RTM vs. RPM codes.

The first distinguishing factor between RTM and RPM can literally be found in the name. RTM seeks to collect and monitor non-physiologic patient data related to therapeutic interventions, such as treatment plan adherence and tolerance to musculoskeletal and respiratory conditions (e.g., HEP adherence, pain pre- and post-exercise, and outcomes tracking). RPM, on the other hand, pertains to collecting and monitoring of physiologic patient data (e.g., heart rate, blood pressure, blood glucose, weight, and physical activity). This is why RPM is sometimes referred to as remote physiologic monitoring.

Next, while both RTM and RPM require the use of a medical device, RTM data can be self-reported by a patient in addition to digitally uploaded via a connected device. In contrast, RPM data cannot be self-recorded or manually entered into a device by a patient—rather, the device must automatically do this.

Lastly, RTM codes are classified as “general medicine” codes—a classification that therein enables PTs, OTs, and SLPs to directly provide and bill for RTM services. By contrast, RPM codes are defined as evaluation and management (E/M) codes, which only permit physicians and nurse practitioners to order and bill for them. 

What are the RTM CPT codes?

As mentioned, CMS introduced five new RTM CPT codes—classified as general medicine codes—in the 2022 final rule. This was followed by the introduction of a sixth RTM code in the 2023 final rule. These codes, and their respective national reimbursement amounts, are outlined here:

 *Reimbursement rates for RTM codes will vary depending on the region.  

How often can RTM codes be billed?

The six codes available for use with RTM all have separate billing frequencies that can either coincide with each other or occur separately over the course of an episode of care (EOC). Here’s the breakdown:

• Code 98975 may be billed once per EOC, which starts when the remote therapeutic monitoring service initiates and ends once targeted treatment goals are attained.
• Codes 98976, 98977, and 98978 may be billed once per 30 days.
• Code 98980 may be billed once per calendar month for the first 20 minutes of care, regardless of the number of therapeutic monitoring modalities performed in that calendar month. 
• Code 98981 may be billed once per calendar month for each additional 20 minutes completed within that month.

Furthermore, codes 98980 and 98981 are treatment management codes meant to cover the time spent monitoring patient data, which must be done by a qualified healthcare professional. These codes apply to a calendar month, are time-dependent, and require at least one synchronous communication session—like a phone call visit. However, text conversations do not fall under the synchronous communication purview, and therefore are not billable.

What supervision level is required to furnish RTM services?

As of 2023, PTs, OTs, and SLPs aren’t eligible to bill Medicare “incident to,” which means that private practice therapy assistants (and other clinical staff) are unable to furnish RTM services under general supervision requirements. Therefore, RTM must either be furnished directly by a qualified healthcare practitioner (i.e., PT, OT, or SLP) or by a therapy assistant under the direct supervision of a PT, OT, or SLP. However, therapy assistants who practice in a non-private setting (e.g., hospitals or rehabilitation clinics) can furnish RTM under general supervision guidelines.

Currently, CMS is working to address billing and supervising limitations as they relate to providing RTM services. 

How many therapists are currently billing for RTM?

RTM remains a relatively new player in the rehab therapy industry, but (as we mentioned in our RTM webinar), we have seen a considerable increase in RTM CPT code usage among WebPT Members using the Keet RTM Dashboard. Between January 2022 and January 2023, we recorded 5,000 instances in which codes 98975 and 98977 were billed. Seventy percent of these RTM users were from small practice segments (practices with 16 or fewer providers) and 20% of RTM users were from mid-market clinics (practices with 17-149 providers).

In the grand scheme of things, this may not seem like a lot, but it’s important to note that 2022 was also the year these codes were introduced—so it’s likely that these numbers will continue to increase as more therapists start to understand RTM and its benefits.

What devices can be used for RTM?

To participate and bill for RTM, a specific medical device must be used, and it must meet the standards set forth by the FDA for what constitutes a medical device. That means it needs to be:

• “Recognized in the official National Formulary, or the United States Pharmacopoeia, or any supplement to them”;
• Intended to diagnose or help cure, mitigate, treat, or prevent diseases or other conditions; 
• Intended to affect the body without (or nearly without) chemical action; and 
• Not reliant on metabolization. 

Of note, the FDA does not issue certificates for devices that are registered with the agency, so be wary of any companies promoting their products as such. 

Devices also aren’t limited to what you can hold in your hands; the FDA allows for Software as a Medical Device (SaMD), which makes RTM that much more accessible. In fact, a great way to comply with RTM device requirements is to find software that makes it easy to engage with and monitor patient progress through an app—like Keet Health.

What is the cost associated with RTM devices?

Currently, RTM devices and software are priced on a platform-by-platform basis. However, we do know that CMS is continuing to seek commentary on what types of RTM devices are being used and the costs associated with each in order to reflect these aggregate costs within their current methodology.

For the time being, we’ve created a handy RTM calculator that can help determine the potential revenue impact RTM may have on your clinic. You can use it as a barometer for what you’re willing to spend on an RTM device/software once you start shopping around.

How does RTM benefit rehab therapists?

Implementing a new service into an already busy work schedule can prove difficult—and maybe even daunting—for staff PTs at first glance. But there are a wealth of reasons to justify why RTM is a benefit to rehab therapists and their patients. Here are the main ones.

RTM can improve patient outcomes through heightened engagement and adherence.

Getting improved patient outcomes requires meeting patients on their terms—which cannot be achieved if the patient is not invested in their plan of care or they do not follow through on their role in rehab therapy. RTM creates a method to follow up and reinforce what rehab therapists painstakingly try to achieve with in-person care: behavior modification through engagement and adherence.

Through proper application of the RTM codes, rehab therapists can check on patients’ MSK and respiratory statuses, including:

• pain,
• sleep patterns,
• HEP adherence,
• correct exercise performance, or
• modifying treatment plans.

From here, therapists can gauge where patients are keeping pace with their treatment and where they might require additional support, education, and/or encouragement. They can also communicate directly with patients in some RTM applications, answering care-related questions in real-time to avoid treatments from stalling out. 

Although the research for RTM is still limited, their RPM code counterparts have proven to help improve patient experience and outcomes and greater medication adherence—a promising sign of what we’ll (hopefully) soon learn about RTM’s efficacy.

RTM helps therapists collect more—and better—data.

Data collection leads to better results in patient outcomes. Period. And while we all know this to be true, properly collecting, tracking, and utilizing patient data remains a difficult hurdle for many therapists and clinic owners alike. However, RTM makes this process much more streamlined, helping rehab therapists capture more (and often new), high-quality data about their patients’ lifestyles and health-related habits. Gaining a more holistic view of patients can help drive better clinical decision-making, and thus, greater patient experience, better outcomes, and improved medication adherence.

RTM offers an additional revenue source.

In an era where all healthcare providers are being pinched by payers, the returns for billing RTM codes can be significant. As seen in this blog post, a therapist could potentially bill for an additional $160 per patient using RTM codes, in certain cases. And all for work that was likely being done previously—before it was reimbursable—to help patients achieve their treatment goals.

(Check out our RTM Revenue Calculator to see how much additional revenue RTM can unlock in your practice.)

RTM can reduce barriers to care.

Per the CDC, more than 46 million Americans live in rural communities. That’s 15% of the US population who potentially live in regions without suitable access to health care, making routine visits difficult and expensive. These healthcare deserts present a costly dilemma for the medical field. In response, CMS has launched a series of initiatives to reach this vulnerable group—which include (you guessed it!) RPM and RTM codes.

By utilizing RTM for patients suffering from housing instability, transportation needs, utility difficulties, or interpersonal safety, PTs can reach a segment of the population often overlooked and forgotten—and save everyone (patients, payers, and themselves) on costs. Yet another leap forward in the strides the healthcare community is taking toward value-based care!

How can rehab therapists use RTM in practice?

Change is difficult for any person regardless of age or background, and with the novelty of RTM codes, hiccups are sure to be encountered along the way. But, with a little guidance rehab therapists can use RTM codes to diversify the typical workflow, decrease pressure on visit frequencies, and focus care on a more patient-centric model of rehabilitation.

Automate clinical care pathways.

It is no secret in private practice settings that front office staff are often overworked and forced to triage many different clinic operations. RTM can help alleviate some of these stressors by automating how patients receive plans of care and home exercises after their initial visit. From there, patients can initiate their treatment plan by engaging with the RTM software—without having to involve the front office.

Fill in scheduling gaps with RTM. 

Cancellations and no-shows are the banes to every clinic director’s productivity KPIs. But with RTM, you make a significant dent in lost productivity due to these scheduling gaps. Clinicians can effectively use this downtime to initiate an “interactive communication” (which applies to codes 98980 and 98981) or check the RTM dashboard. This serves as a great solution for therapists to get ahead of the inevitable and still maximize their billable work.

Use RTM to reach inaccessible or immobile patients.

The benefits of RTM for patients living in rural or underserved communities were mentioned previously, but there are other individuals that could benefit from RTM’s accessibility. For example, patients with long work hours or with childcare dependencies have increased difficulty in keeping a regular frequency of in-person PT visits. Using RTM to supplement the traditional PT visit, patients can overcome these challenges and create meaningful interactions with their providers and still work toward their goals and a positive outcome.  

Shift PTAs and OTAs to RTM tasks.  

While there may be some billing considerations to keep in mind, PTAs and OTAs can be invaluable assets in implementing and managing RTM in your clinic. Under current supervision guidelines, as defined by CMS, they can be tasked with helping to educate patients on RTM software as well as monitoring patient activity through an RTM dashboard—with some caveats. 

As mentioned above, CMS has stated that outpatient PTAs and OTAs in non-private practice settings—such as hospitals or rehabilitation agencies—can furnish RTM under general supervision guidelines. However, PTAs and OTAs in private practice must be under direct supervision when furnishing two-way audio/visual communication (read: RTM services).

Additionally, remember that state practice acts can supersede these directives, so check your local state’s determination on supervision requirements before adding RTM services to your therapist assistants’ workloads.   

Is there an example of what RTM coding looks like?

Putting into practice a novel treatment program like RTM will come with some aches and pains. To triage some of this, a case scenario can go a long way to paint a clearer picture of what to expect when documenting for RTM. The following table provides such a scenario with a timeline and general criteria for billing the specified units.

*CPT code 98975 can be billed once per EOC, so it could be billed at any time during the EOC. Per this example, we recommend doing so on the day the set up was done, but some clinicians may opt to wait and bill 98975 in conjunction with 98977 to simplify their claims practices as well as to ensure RTM has occurred once the device was set up.

In this EOC that spanned two months, seven units of RTM codes were able to be billed. Notably, 98975 was billed on the day set up was done, and 98977 was billed 30 days after the EOC started to ensure that the therapists had 30 days’ worth of data transmission and monitoring to report (only 16 days of device usage is required, but operationally this example billed 98977 at the conclusion of 30 days to simplify the example). At the end of April, a month had transpired so 98980 and 98981 were able to be billed as 40 minutes of data monitoring and interpretation with one interactive communication (not a telehealth visit) occurred. From April 27, 2022, through May 26, 2022, 30 more days of RTM occurred, as well as another month of management services that included two interactive communications—all of which totaled 40 minutes, allowing 98977, 98980, and 98981 to be billed.

How can rehab therapists get patients on board with RTM?

Not every patient can come into therapy three or more times a week, and others that have the time may not have the money due to the increased costs of high deductibles and copays. With this in mind, the benefits of enacting RTM in rehab therapy cannot be ignored. Luckily, patients are looking for this kind of change and digital solutions are at the forefront of patient desires. 

For example, in the WebPT and Clincient Patient Experience report, 81% of respondents 60 and older received a paper HEP, despite the fact that 41% said they would prefer digital HEP.  What’s more, in WebPT’s recent RTM webinar, Susan Lofton, MPT, WebPT’s VP of Outcomes and Clinical Transformation commented that in the current pool of RTM users recorded within the Keet Health app, the majority of patient participants fell into the late-50 to early-70 age range. This contradicts the stigma that technology usage is only for the young, further expanding the potential pool of RTM candidates.

But, how do you ensure patients fully understand the why and how of RTM? We’ve got a few suggestions on this topic, which were taken from WebPT’s downloadable RTM guide. These include:

• Explaining what exactly RTM is—a means of collecting data on how they’re adhering and responding to treatment. 
• Explaining why the data collected through RTM is important. Not only will it help them engage with their treatment and reduce the number of trips they need to make to the clinic, but it will also help their therapist understand what’s working in their treatment, what isn’t, and adjust accordingly.  
• Walking patients through the process of downloading and/or using the RTM device, including how to connect to the Internet or Bluetooth. Then, show them where they can go to access their programs and educational materials—and where to turn should they need help. 
• Continuing to examine your educational process to see where it can improve, especially if you see patients not using RTM or leaving feedback that they don’t fully understand it.

Want to get started growing your caseload and diversifying revenue streams with RTM?

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