RTM may be a beneficial option for any practice delivering healthcare for those experiencing high incidence of COPD, and/or chronic asthma. The Propeller medical device provides clinicians objective device-generated data as well as subjective inputs reported by a patient on medication adherence, triggers, and exacerbations, to help enable informed care decisions and have open conversations between patients and their families.

According to the CMS 2021 Physician Fee Schedule final rule, Remote Physiologic Monitoring codes involve the collection and analysis of patient physiologic data used to develop and manage a treatment plan related to a chronic and/or acute health illness or condition.Section 84542 of CMS “Medicare Program, CY 2021 Payment Policies under the Physician Fee Schedule and Other changes to Part B Payment Policies” Final Rule. December 2020. https://www.govinfo.gov/content/pkg/FR-2020-12-28/pdf/2020-26815.pdf RPM codes focus on physiologic data that is widely understood to be parameters generated by the human body (e.g. ECG, blood pressure, etc.) detectable by a signal acquisition medical device. RTM codes allow for the monitoring of “nonphysiologic data.” The main differences are the types of data collected and how. As noted in the CPT® Professional 2023 Codebook, remote therapeutic monitoring services (e.g., respiratory system status, therapy adherence, therapy response) represent the review and monitoring of data related to signs, symptoms, and functions of a therapeutic response. These data may represent objective, device-generated integrated data or subjective inputs reported by a patient. These data are reflective of therapeutic responses that provide a functionally integrative representation of patient status.Section 69648 of CMS “Medicare Program, CY2023 Payment Policies under the Physician Fee Schedule and Other change to Part B Payment and Coverage Policies” Final Rule. November 2022. https://www.federalregister.gov/documents/2022/11/18/2022-23873/medicare-and-medicaid-programs-cy-2023-payment-policies-under-the-physician-fee-schedule-and-other#p-1942 For all remote monitoring services, a device as defined in section 201(h) of the Federal Food, Drug and Cosmetic Act (FFDCA) must be used to perform the services. Propeller’s inhaler sensors meet this definition and have received FDA clearance.

RTM codes are classified as General Medicine services. Physicians and eligible qualified healthcare professionals (e.g., physicians assistant (PA), nurse practitioner (NP), clinical nurse specialist (CNS), certified nurse midwife (CNM)), in addition to and other nonphysician healthcare professionals including physical therapists and occupational therapists are permitted to bill RTM services. Section 69642 of CMS “Medicare Program, CY2023 Payment Policies under the Physician Fee Schedule and Other changes to Part B Payment and Coverage Policies” Final Rule. November 2022. https://www.govinfo.gov/content/pkg/FR-2022-11-18/pdf/2022-23873.pdf

Yes, depending on the reporting provider and requirements of the applicable plan. A physician or qualified healthcare professional (e.g., PA, NP, CNS, CNM) provider may report some aspects of RTM services that are performed “incident to” by clinical staff/auxiliary personnel under the provider’s general supervision. However, providers must verify current requirements and coverage policies as stipulated by each individual payer.Section 69649 of CMS “Medicare Program, CY2023 Payment Policies under the Physician Fee Schedule and Other changes to Part B Payment and Coverage Policies” Final Rule. November 2022. https://www.govinfo.gov/content/pkg/FR-2022-11-18/pdf/2022-23873.pdf

No, physicians cannot bill for the same patient for both RTM and RPM in the same 30 day period. Providers must assess whether RPM or RTM are reasonable and necessary given a patient’s medical condition and consider which service most adequately describes their work. Section 65115 of CMS “Medicare Program, CY 2022 Payment Policies under the Physician Fee Schedule and Other changes to Part B Payment Policies” Final Rule. November 2021. https://www.govinfo.gov/content/pkg/FR-2021-11-19/pdf/2021-23972.pdf

Yes. RTM professional service codes (98980, 98981) may be billed independently from the RTM device codes (98975, 98976).Section 65115 of CMS “Medicare Program, CY 2022 Payment Policies under the Physician Fee Schedule and Other changes to Part B Payment Policies” Final Rule. November 2021. https://www.govinfo.gov/content/pkg/FR-2021-11-19/pdf/2021-23972.pdf

Code 98980 requires at least 20 minutes of intraservice work by the reporting provider, including at least one interactive communication (i.e., a real-time, synchronous, audio conversation with the patient/caregiver) as part of the 20-minute increment. Code 98981 has the same requirement but is used to report each additional 20-minute increment thereafter. Section 65115 of CMS “Medicare Program, CY 2022 Payment Policies under the Physician Fee Schedule and Other changes to Part B Payment Policies” Final Rule. November 2021. https://www.govinfo.gov/content/pkg/FR-2021-11-19/pdf/2021-23972.pdf

In order to report RTM codes 98975 and 98976 the patient must use a medical device which reports at least 16 days of medical device monitoring data. If at least 16 days of medical device data are not reported, the professional codes may not be reported for that period. Section 65115 of CMS “Medicare Program, CY 2022 Payment Policies under the Physician Fee Schedule and Other changes to Part B Payment Policies” Final Rule. November 2021.
https://www.govinfo.gov/content/pkg/FR-2021-11-19/pdf/2021-23972.pdf

RTM codes may be billed during the same service period as chronic care management services, transitional care management services, principal care management services, behavioral health integration services, and psychiatric collaborative care services. However, time spent performing all services should remain separate from each other and no time may be counted toward the required time for both services in a single month. Providers should work with a billing advisor or other expert to help determine whether it is appropriate to bill different combinations of codes.Section 65115 of CMS “Medicare Program, CY 2022 Payment Policies under the Physician Fee Schedule and Other changes to Part B Payment Policies” Final Rule. November 2021. https://www.govinfo.gov/content/pkg/FR-2021-11-19/pdf/2021-23972.pdf