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By HealthArc
| December 28, 2023
The Centers for Medicare & Medicaid Services (“CMS”) recently issued its long-awaited Physician Fee Schedule Final Rule for CY 2024 after much revision and clarification. The new policies reimbursed under the Medicare Program and part of Remote Monitoring Services are related to Remote Physiologic Monitoring (RPM) and Remote Therapeutic Monitoring (RTM).
Below is a summary of key changes introduced in the Final Rule relating to RPM, RTM, and other virtual care management services starting January 1, 2024. From general supervision to coverage expansion and more, here are the key updates in the RTM billing final rule you must be aware of:
1. PTs & OTs Can Bill RTM for Assistants Under General Supervision Outside Of Private Practice
The foremost provision allows general supervision of outpatient therapy services for Physical Therapists (PTs) and Occupational Therapists (OTs) in private practice. This highly important provision now provides the flexibility to physical therapists and occupational therapists working in private practice to provide general supervision for RTM services furnished by their PTAs and OTAs.
This update will provide the right support to the RTM management services performed outside of the clinic, mainly covering comprehensive at-home support for patients.
2. No 16 Days Data Requirement For RTM Treatment & Management
In the Final Rule, CMS clarified which remote monitoring codes do not require at least 16 days of data collection in 30 days. It stated that the 16-day data collection requirement does not apply to CPT codes 99457, 99458 (RPM), and 98980, 98981 (RTM). These RTM codes are treatment and management codes that account for time spent on patients in a calendar month.
3. RTM Reimbursement Coverage In RHCs and FQHCs
CMS has finalized that starting in 2024, Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) will bill Medicare separately for RPM and RTM services under the general care management code, HCPCs code G0511. For reimbursement coverage, RTM services must be medically reasonable and meet all the coding requirements for an episode of care given in a calendar month.
Both RHCs and FQHCs may bill HCPCS code G0511 multiple times in a calendar month. To ensure access to healthcare for underprivileged populations in rural locations, CMS encourages early intervention with conservative therapies and promotes health equity.
4. Billing RTM During Global Surgical Periods
In 2024, providers receiving a global service payment may not bill for RTM services. If a practitioner furnishes a procedure or surgery subject to a global billing period, he/she cannot bill it for Medicare. During the global surgical period, the global billing payment received by the practitioner covers the post-surgical follow-up service expenses during the period.
Physical therapists or occupational therapists who are not receiving a global service payment are permitted to provide RTM services and can enroll the patient in the therapist’s RTM program for post-surgery rehab and monitoring.
5. 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.
As per the current RTM rules, the failure to conduct an initial patient evaluation and create an “established patient” relationship may not deviate from RTM billing requirements, but failing to complete initial interaction and creating a treatment plan could result in post-payment audits to practitioners.
6. Use of RTM With Other Patient Care Management Services
When it comes to Medicare billing, practitioners are permitted to bill either for RPM or RTM (but not both RPM and RTM) and concurrently bill along with the following care management services, as long as the time and effort is not counted twice:
- Chronic Care Management (CCM)
- Transitional Care Management (TCM)
- Behavioral Health Integration (BHI)
- Principal Care Management (PCM)
As per the Final Rule for RTM Medicare billing advice formulated by the CMS, the above-discussed changes will come into effect starting January 2024.
To keep our clients updated with the latest modifications to the RTM billing structure, HealthArc is dedicated to implementing all updates. Our focus is on enhancing our virtual healthcare systems and clinical software for superior patient outcomes and efficient billing.
For questions on RTM services or demo, feel free to talk to our team at +201 885 5571.
