RPM & RTM Info 2024
RPM and RTM Clarifications
1. RPM Can Only be Furnished to an Established Patient
RPM services are once again limited to “established patients” as of May 2023. An established patient is any individual who has received any professional services, evaluation-and-management (E/M) service, or other face-to-face service (surgical procedure for example) from this provider or another provider in the same specialty and same group practice within the previous three years. While RPM services require an established patient relationship prior to billing RPM codes, RTM technically do not. CMS confirmed in the 2024 Final Rule, “RPM, not RTM, services require an established patient relationship after the end of the PHE.”
2. RTM Does Not Contain an Established Patient Requirement
RTM services technically do not require an established patient relationship before billing codes. CMS expressed its belief that RTM services would be furnished to a patient only after a treatment plan has been established after the initial evaluation.
3 .Practitioners Must Collect at Least 16 Days of Data Per 30-Day Period
Data needs to be collected for at least 16 days in a 30-day period for remote monitoring services after the Public Health Emergency (PHE) expired in May 2023. This rule is applicable to existing RPM and RTM code families for the calendar year 2024. In the 2024 Final Rule, CMS notes that “in the CY 2024 PFS proposed rule, we inadvertently listed all of 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.”
4. Only One Practitioner Can Bill Medicare for RPM/RTM Services
Specific CPT codes (99453, 99454 for RPM; 98976, 98977, 98980, 98981 for RTM) can only be billed by one practitioner in a 30-day period (episode of care, not a calendar month). However, other services like Chronic Care Management (CCM), Transition Care Management (TCM), Behavioral Health Integration (BHI), Principal Care Management (PCM), and Chronic Pain Management (CPM) can be billed concurrently with either RPM or RTM.
5. RPM is Not Included in the Definition of Primary Care Services for MSSP
RPM is Not Included in the Definition of Primary Care Services for MSSP. In the Proposed Rule, CMS considered adding RPM CPT codes 99457 and 99458 to the definition of primary care services used for purposes of beneficiary assignment in the Medicare Shared Savings Program (MSSP).
2024 RPM CPT Codes
99453: Initial set-up & education
Remote monitoring of physiologic parameter(s) (e.g., weight, blood pressure, pulse oximetry, respiratory flow rate), initial; set-up and patient education on use of equipment.
Reimbursement: $19.65 (One-time)
99454: Transmission of data
Remote monitoring of physiologic parameter(s) (e.g., weight, blood pressure, pulse oximetry, respiratory flow rate), initial; device(s) supply with daily recording(s) or programmed alert(s) transmission, each 30 days.
Reimbursement: $46.83 (Every 30 days)
99457: Management services for initial 20 minutes
Remote physiologic monitoring treatment management services, clinical staff/physician/other qualified healthcare professional time in a calendar month requiring interactive communication with the patient/caregiver during the month; first 20 minutes.
Reimbursement: $48.14 (Monthly)
99458: Management services for each additional 20 minutes (add-on to 99457)
Remote physiologic monitoring treatment management services, clinical staff/physician/other qualified health care professional time in a calendar month requiring interactive communication with the patient/caregiver during the month; each additional 20 minutes. Note: From our billing experience and the MUE for the 99458 code that 3 units (60-minutes) is the max amount Medicare will pay and some commercial claims only paid for 2 units (40-minutes).
Reimbursement: $38.64 (Monthly)
99091: Collecting and analyzing physiologic data
Collection and interpretation of physiologic data (e.g., ECG, blood pressure, glucose monitoring) digitally stored and/or transmitted by the patient and/or caregiver to the physician or other qualified health care professional, qualified by education, training, licensure/regulation (when applicable) requiring a minimum of 30 minutes of time, each 30 days.
Reimbursement: $52.71 (Every 30 days)
*Note that the actual reimbursement rates may vary. Fees above based on the 2024 national average non-facility-based payment from CMS.
2024 RTM CPT Codes
98975: Initial setup & education
Remote Therapeutic Monitoring (e.g., respiratory system status, musculoskeletal system status, therapy adherence, therapy response); initial set-up and patient education on the use of equipment.
Reimbursement: $19.65 (One-time)
98976: Device supply for respiratory system
Remote therapeutic monitoring device(s) supply with scheduled (e.g., daily) recording(s) and/or programmed alert(s) transmission to monitor the respiratory system.
Reimbursement: $46.83 (Every 30 days)
98977: Device supply for musculoskeletal system
Remote therapeutic monitoring device(s) supply with scheduled (e.g., daily) recording(s) and/or programmed alert(s) transmission to monitor the musculoskeletal system.
Reimbursement: $46.83 (Every 30 days)
98980: Management services for initial 20 minutes
Remote Therapeutic Monitoring treatment management services, physician/other qualified health care professional time in a calendar month requiring at least one interactive communication with the patient/caregiver during the calendar month; first 20 minutes
Reimbursement: $49.78 (Monthly)
98981: Management services for each additional 20 minutes (add-on to 98980)
Remote therapeutic monitoring treatment management services, physician/other qualified health care professional time in a calendar month requiring at least one interactive communication with the patient/caregiver during the calendar month.
Reimbursement: $39.30 (Monthly)
*Note that the actual reimbursement rates may vary. Fees above based on the 2024 national average non-facility-based payment from CMS.