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This webinar was recorded on November 15, 2023 and covers the CY2024 Medicare Physician Fee Schedule final rule. Remote Therapeutic Monitoring and MIPS requirements have changed since then. For current guidance, see RTM CPT Codes 2026: New Codes, Rates and Final Rule Changes and our webinar Navigating the 2025 CMS Final Rule.
Rick Gawenda, PT, and Jake Grundstein, PT, DPT, reviewed how the CY2024 final rule affected Remote Therapeutic Monitoring (RTM) and the Merit-based Incentive Payment System (MIPS), and what rehab therapy practices needed to prepare for in 2024.
The webinar describes the 2024 rules, when RTM device supply codes and 98975 required at least 16 days of data in a 30-day period and treatment management started at 20 minutes. Effective January 1, 2026, CMS added CPT 98985 for 2 to 15 days of musculoskeletal device data and CPT 98979 for 10 to 19 minutes of treatment management. Payment amounts quoted in this webinar are 2024 estimates. See our 2026 RTM CPT code guide for current codes and rates.
Rick Gawenda, PT, President of Gawenda Seminars and Consulting; Jake Grundstein, PT, DPT, Vice President of Clinical Operations and Value-Based Care at Limber Health at the time of recording; moderated by Josie of Limber Health.
This transcript was generated from the recording and lightly edited for readability.
Josie Andino [0:01]: Let's get started. Welcome to First Look at the Final Rule, where we'll cover the impact the rule had on RTM and MIPS. We're thrilled to go over everything that came out in the rule a couple of weeks back. We'll start with a brief overview of RTM and MIPS, then cover how the final rule affects RTM, then how it affected MIPS, and we'll close with Q&A. A few housekeeping items: all of your lines will be muted during the webinar, and you're welcome to submit questions in the Q&A box. Rick, Jake, and I will be moderating and answering those questions. If we don't get to your question, we'll follow up one-on-one. This webinar is being recorded and will be shared with you by email. We're thrilled to be joined today by Jake Grundstein from the Limber team and Rick Gawenda. Jake, I'll let you take it away.
Jake Grundstein [1:07]: Thank you, Josie. I'm excited to be here talking with you all today. My name is Jake Grundstein, and I'm the Vice President of Clinical Operations and Value-Based Care at Limber. I'm a physical therapist by training, and I spent most of my career at Hospital for Special Surgery in New York, where I treated in one of the outpatient clinics and later moved into an operations and value-based care role. I joined Limber and have been with the company pretty much since we started, building out the roadmap for what RTM and MIPS look like from a clinical operations perspective. I'll pass it over to Rick, and then we'll get started.
Rick Gawenda [1:46]: Thanks, Jake, and good afternoon or good morning to everyone. Thanks for joining us. My name is Rick Gawenda, and I'm the president and founder of Gawenda Seminars and Consulting. Like Jake, I'm a PT, and I've been one since 1991, but for the last 20 years I've focused on the compliance side as a consultant and educator. I focus on outpatient PT, OT, and SLP: coding, documentation, billing, productivity, and ways to add other revenue streams to your business, two of which we're talking about today, RTM and MIPS. Happy to be doing this with Josie, Jake, and the Limber team.
Jake Grundstein [2:29]: Like Josie said, we're going to set the foundation with a bit of history and definition around Remote Therapeutic Monitoring, and then Rick will take us into the final rule. Some of you may be familiar with RTM, but I wanted to share how we've always thought about its benefits at Limber and how we see it affecting patient care. We see it improving the experience for patients as well as for providers.
One of the frustrations I always felt when I was treating patients was when they came back in and said, "I didn't have time to do my exercises," or "I didn't know how to do them." I always told patients that I couldn't change 30 years of low back pain by seeing them in the clinic twice a week if they kept doing the same things at home and didn't bring their activity modification and plan of care into their home environment. We know that about 80% of a patient's outcome is determined by their behavior outside the clinic, and less than 35% of patients adhere to their home exercise program. That's a huge gap, and we feel that Remote Therapeutic Monitoring and home support and engagement can help close it. We also know that about 80% of the information told to patients is immediately forgotten. That's no fault of theirs. A lot of information gets shared at an initial evaluation, and it can be overwhelming, so patients sometimes pick and choose what they listen to.
Jake Grundstein [4:05]: Finally, patients who receive communication between visits are 94% more likely to adhere to their HEP. When I see these numbers, I see a lot of room for home engagement and support, and that can be done through remote monitoring. I think every PT can agree we'd love to have more information about what our patients are doing at home. As a treating PT, most of the time I'd find out that an exercise caused pain at the next in-clinic visit, unless the patient was forward-thinking enough to email me. With RTM, we can get much more real-time information about what patients are doing at home, which is an exciting thing for the industry.
Remote Therapeutic Monitoring is a family of CPT codes designed to increase patient adherence and improve outcomes, because patients are hopefully doing their program more. RTM is delivered with two things. You need the digital technology, which collects the data and helps in-clinic providers understand what's happening with their patients at home. And you need clinical staff to engage the patient when they're outside the clinic. When people hear about digital technology, they sometimes think it's going to replace their job. This service isn't intended to do that. It's intended to augment the patient experience and the provider experience by providing support outside the clinic, and we see it as a great way to continue patient care.
Jake Grundstein [5:52]: A brief history of Remote Therapeutic Monitoring and the codes themselves. In 2019, CMS approved remote patient monitoring, and the AMA created CPT codes for it. One of the nuances of RPM is that it required physiologic monitoring, such as blood pressure and heart rate. That sometimes plays a role in orthopedics, but in physical therapy the patient-reported side and exercise completion are the big things. Our leadership team was heavily involved in this process, and the value we communicated was that these codes could affect MSK care downstream and produce real savings in healthcare spending as the patient moves through their care.
In early 2020, we saw a gap for MSK and respiratory patients. The RTM codes were created and submitted in late 2020, approved in 2021, and assigned RVU values, which Rick will go through. In January 2022, the RTM codes went live and could be reimbursed for physical therapists. In the MSK and respiratory space there are five codes associated with Remote Therapeutic Monitoring. They're covered by Medicare, and we're seeing more commercial payers pick them up as the value becomes clear.
Jake Grundstein [7:20]: I'll go quickly through the five codes. The first code, 98975, is the enrollment and initial setup code. It can be billed one time per episode once 16 days of data transmission are met. Data transmission is the patient using the app and submitting their data. The next two codes, 98976 and 98977, are the data tracking codes, covering things like home exercise program adherence, outcomes, and pain scores. 98976 is used for respiratory patients and 98977 for musculoskeletal patients, and they can be reimbursed once 16 days of data transmission are met in a 30-day period. That's an important difference from the next two codes.
98980 and 98981 are the care management codes. That's the time spent doing Remote Therapeutic Monitoring, whether that's talking with the in-clinic provider, talking with the patient, or making sure patients stay engaged in their program. The first 20 minutes is 98980, and each additional 20 minutes after that is 98981. These can be billed every calendar month, which is different from 98976 and 98977.
Jake Grundstein [9:01]: Finally, MIPS. CMS is continually looking for ways to move providers toward value-based care, and MIPS is that glide path. It puts quality, outcomes, and cost in the forefront of providers' minds. MIPS has four categories. Quality focuses on the quality of care provided, and that's where you'll see patient-reported outcome measures and process measures. Improvement activities evaluate provider engagement in activities that improve patient care and care coordination. Promoting Interoperability evaluates the use of the electronic medical record. And cost evaluates the total cost of care for the patient panel a provider is seeing, using Medicare claims. With that, I'll pass it to the one and only Rick Gawenda to take you through the final rule and the changes coming in 2024.
Rick Gawenda [10:11]: Thanks, Jake. I'm sure you've all read the final rule and know it well. It's just over 2,700 pages, and it will be published officially in the Federal Register tomorrow. Today we're focusing only on RTM and MIPS, so we won't be covering the conversion factor, assistant supervision for in-person services, and the rest. The goal is to give you a high-level overview of what I think are positive changes for next year and how you can implement both in your practice.
Let's look at the RTM changes for 2024, and this is a big one: general supervision. CMS, the Centers for Medicare and Medicaid Services, did a carve-out. As you know, in private practice, if an assistant is treating a Medicare beneficiary in an in-person visit, we have the modified definition of direct supervision, which means the therapist must be available by real-time, two-way audio-video telecommunication. That didn't make sense for RTM, because RTM isn't a visit. It's something different, done over a 30-day period. So in the private practice setting, CMS will allow general supervision of the PT assistant and OT assistant when they're furnishing RTM to a Medicare beneficiary.
Rick Gawenda [11:40]: You all have state practice acts, and the Limber team and I are aware of a couple of states with unusual direct supervision requirements. If your state still requires direct supervision, meaning the therapist must be on the premises, your state practice act overrules Medicare, so you'd have to follow your state practice act. This is a big change for the vast majority of private practices in the vast majority of states.
The other thing: if you have an unenrolled PT or OT doing RTM on a Medicare patient, they need direct supervision by an enrolled therapist. I don't recommend that, because an unenrolled PT or OT creates a billing issue. From a supervision standpoint you can do it, but from a billing standpoint you need to get those therapists credentialed with Medicare. Once the Medicare contractor has received the application, they can start seeing Medicare beneficiaries. You just hold the claims until the application is approved, and you'll have a retrospective billing date.
Rick Gawenda [13:20]: CMS once again clarified that RPM and RTM cannot be billed during the same time period. Say you're in a physician-owned practice where the physician is doing remote physiologic monitoring on a patient and refers that patient to physical therapy, and the PT wants to implement Remote Therapeutic Monitoring. The physician would have to decide whether to do RPM or RTM.
Also, when the proposed rule for 2024 came out in July 2023, CMS made a mistake. The proposed rule said 98980 and 98981 required 16 days of data recording or transmission every 30 days in order to bill those two codes. We knew that was a mistake and pointed it out, and in the final rule that came out on November 2, CMS clarified that the 16 days of data recording and transmission do not apply to 98980 and 98981. That's a good thing.
Rick Gawenda [14:42]: Another thing we pushed very hard on, and by we I mean APTA, APTA Private Practice, Limber, and many RTM vendors, was asking CMS to allow more than one discipline to do RTM at the same time and have each discipline bill for its time. The example we used was a Medicare beneficiary who falls and fractures their right wrist and their left hip, then comes to Jake and Rick's Physical Therapy, where they see a PT for the hip and an OT for the wrist. OT could set that patient up on an RTM program for the wrist, and PT could set them up on an RTM program for the hip. They're two different things, and each discipline would bill 98980 and the other codes Jake described when the requirements are met.
Unfortunately, CMS didn't agree. They said multiple medical devices can be used, but the services associated with all of the devices can be billed by only one practitioner, only once per patient, per 30-day period. So in that example, 98977 could not be billed by both PT and OT. All devices are considered together, and only one discipline can bill the applicable CPT codes.
Rick Gawenda [16:27]: Next, the global service. People were worried about physician-owned practices. Say a physician does a total knee replacement and refers the patient to a physical therapist in their own practice, or refers the patient to Jake and Rick's Physical Therapy, where we have no relationship with that physician. The proposed and final rule said the policy prohibits RPM and RTM services from being furnished during the global period. We pointed out that a physician does a knee replacement and might send the patient to a hospital outpatient department or a private practice that's unaffiliated with the physician.
CMS clarified that the policy prohibiting RPM and RTM during a global period applies only to the billing practitioner receiving the global service payment. In the knee replacement example, that's the physician, not the therapist. The final rule says practitioners such as therapists who aren't receiving a global service payment, because they didn't furnish the global service, are permitted to furnish RPM or RTM during the global period. Jake and I would agree we've never seen a PT or OT do a joint replacement. Because you didn't do the procedure, you're not getting the global payment, which means whether you're a therapist employed by the physician practice or employed elsewhere, you can do RTM.
Rick Gawenda [18:41]: Here are the expected payments for 2024. As it stands today, November 15, we're looking at about a 3.4% payment reduction under the Medicare Physician Fee Schedule in 2024 compared with 2023. These are the expected national payment amounts. Jake, if you can look up the RVUs for 98981 and multiply by the 32.7375 conversion factor, that will give us that number.
When you look at 98975, 98976, and 98977, you don't see any work RVUs because there's no work done by you, the therapist. With 98976 and 98977, it's the patient logging into the app, doing the exercises, and documenting their pain. 98975 is the initial setup of the device with the patient and the patient education and training, telling them what you want them to track. With 98980 and 98981, you'll see work RVUs, because that's you, the therapist or assistant, logging into the app, analyzing and interpreting the data, updating the home exercise program, and calling or emailing the patient.
Rick Gawenda [20:16]: Keep in mind some of you will be higher than these national amounts and some of you will be lower. My hope is that Congress, as it typically does in December, passes an appropriations bill, in this case the Consolidated Appropriations Act of 2024, and provides additional funding to the Medicare program so we don't take a 3.4% reduction. If they do, these payment amounts will go up. And Jake did the math for me: 98981 is $39.28. We'll update the slide when we release the video. So the first 20 minutes, 98980, has a national payment amount of $49.76, and each additional 20 minutes, 98981, is about $39. That's the overview of the final rule as it applies to RTM.
Rick Gawenda [21:17]: Now a brief overview of the MIPS program for 2024, starting with the performance threshold. If you participated in MIPS in 2023, you have to score 75 points out of 100 to avoid a negative payment adjustment in calendar year 2025. For 2024, CMS proposed requiring 82 points out of 100 to avoid a negative payment adjustment in 2026. In the final rule, they backed it down and kept it at 75.
There are pros and cons to this. One pro is that you only need at least 75 points instead of 82, whether you're mandated to participate in MIPS or you opt in. The downside: if it had stayed at 82 points, CMS estimated that a score of 100 in 2024 would have earned an 8.82% positive payment adjustment in 2026. For every $100,000 Medicare would have paid you, you'd have received just over $108,000. Because they went back down to 75, CMS now estimates a perfect score in 2024 would earn only about 4.6% in 2026. So if you have a history of scoring 95, 97, 98, or 100 points, you're probably disappointed it didn't stay at 82. If you've struggled to get to 75 or 76, you're probably happy.
Rick Gawenda [23:47]: Data completeness remains at 75%. If you're still reporting quality measures through Medicare Part B claims, you have to report the applicable measures on 75% of all of your traditional Medicare patients to whom the measures apply. If you're using a QCDR or a registry, which I hope you are, that 75% data completeness applies to all of your patients the measure applies to, which could include Blue Cross, workers' comp, Aetna, Cigna, Humana, and so on.
The one that doesn't make sense to me, and I know to some of the Limber team, is the Promoting Interoperability category. If you've been doing MIPS, we've really had only two categories, quality and improvement activities. For 2024, if you're a large practice, defined as 16 or more MIPS eligible clinicians under the same tax ID number, the Promoting Interoperability category will not be reweighted. If you're a small practice, 15 or fewer MIPS eligible clinicians under the same TIN, it will be reweighted because of previous rulemaking.
Rick Gawenda [25:21]: Based on 2023, what we think will happen is this. In 2023, MIPS eligible clinicians who have to do PI can complete an exception application and give one of four reasons they couldn't do the PI category. My opinion is that in 2024 the same application will be available, most likely with the same four reasons, one being the lack of a certified electronic health record, or that having one is out of your control. If your EMR system isn't certified, you'll need to fill out that application, and we'll probably recommend doing it early, as soon as it opens in 2024, to make sure it's approved.
If you do have a certified EHR, they changed the Promoting Interoperability data collection period from 90 consecutive days to 180 consecutive days. That's why we'll encourage you to apply early. If the application opens in February or March 2024 and you're denied, you still have eight or nine months to figure out how to cover that 180-day period.
Rick Gawenda [27:15]: Now the cost category. A low back pain cost measure will be available to PTs and, believe it or not, OTs in 2024. It will apply to traditional MIPS, which you're used to if you've been doing MIPS, and next year there's also an MSK MVP where all of these categories will apply. Cost is really the one thing out of your control. CMS held a QCDR webinar yesterday, and someone from Limber shared a spreadsheet with me showing 268 different ICD-10 diagnosis codes that would trigger the cost measure. You need 20 episodes of care during 2024 with one of those 268 diagnoses.
For some of you, it's going to trigger. When you look at the CPT codes, essentially all of them trigger it: therapeutic exercise, neuromuscular reeducation, aquatic therapy, gait training, manual therapy, therapeutic activities, self-care, wheelchair management and training, the PT evaluation and re-evaluation codes, and the OT evaluation and re-evaluation codes. You might wonder when OT would treat low back pain. Think of a patient in your outpatient clinic seeing PT for low back pain and OT for something unrelated. If one of those 268 diagnosis codes is on the PT's 1500 claim form, and your billing department for some reason also includes that ICD-10 code on the OT claim form, then when OT bills the evaluation, therapeutic activities, or therapeutic exercise, it could trigger the measure for OT. So make sure the correct diagnosis codes go on the OT claim, and if OT isn't treating the back, those codes don't end up on the OT 1500 claim form. Again, cost is out of your control. It's determined by CMS based on you seeing the patient and the diagnosis and CPT codes on the claim.
Rick Gawenda [30:14]: For quality in the MSK MVP, there will be 10 measures available, and you have to report on four of the 10. My opinion, and only my opinion, is that this will be tough for a lot of you, because seven of the 10 measures are FOTO measures, and many of you don't use FOTO. The eighth is measure 155, falls plan of care, which is only reported if the patient had two or more falls in the past 12 months or one fall with an injury, and you have to be able to report it 20 times. For a lot of practices that doesn't happen. Then there's measure 128, BMI screening, which is a topped-out measure, so even with 100% performance and 100% data completeness, the most you'll get is seven points. Improvement activities in the MSK MVP work just like traditional MIPS: two medium-weighted or one high-weighted activity. And as we discussed, if you're a large practice, Promoting Interoperability applies to you in 2024 unless you submit the application and qualify for reweighting.
Josie [31:55]: Thank you so much, Rick. Jake is going to take you through a little bit about Limber, and then we'll jump into questions.
Jake Grundstein [32:02]: Thank you, Rick. I feel like I learn something every time I hear you speak, so I appreciate the insight. We talked a lot today about MIPS and Remote Therapeutic Monitoring, and I wanted to quickly touch on Limber and what we offer. Limber Health is a digital health company that helps in-clinic partners extend care outside the clinic by increasing patient engagement and tracking patient outcomes. We offer a full Remote Therapeutic Monitoring solution. We do MIPS submission as a QCDR with our own measures. We have an outcomes solution, and we offer a home exercise program platform with more than 5,000 exercises at this point. If you're interested in learning more, feel free to reach out to our team.
Josie [33:00]: Thanks, Jake. I'll put the contact slide back up after questions. Please keep using the Q&A box if you have more questions after hearing Jake and Rick discuss the final rule, RTM, and MIPS. Rick, I'll kick it off with a question about orthopedic surgeons prescribing RTM. Can orthopedic surgeons prescribe RTM during the surgical global period if it's performed by PTs outside their practice?
Rick Gawenda [33:53]: The answer is yes, and it can also be performed by PTs within the physician-owned practice. CMS clarified in the final rule that the prohibition on billing RPM or RTM during the global period applies only to the qualified healthcare professional who actually did the global procedure and was paid for it. Because the PT, whether in the physician practice or a different practice, didn't do the global procedure, they can do RTM.
Josie [34:34]: Thank you. Another question: when do you qualify for MIPS as an organization?
Rick Gawenda [34:41]: Great question. I'll take "qualify" to mean "when are you mandated to report." You can never be mandated to report MIPS as an organization or practice. The only time you can be required to do MIPS is based on the individual NPI and TIN combination. If you want to opt in, say Jake, Julia, and I are all PTs working in a practice together, and none of the three of us is mandated to report because none of us exceeds all three low-volume thresholds during both determination periods. Together, though, we exceed at least one of the three thresholds. We can then decide to opt in and report as a group, but you can never be mandated to report as a group.
Rick Gawenda [35:56]: Before the next question, let me share how the categories will be weighted next year. If you're a small practice, it's 40% quality, 30% cost, and 30% improvement activities. If you're a small practice and you don't meet the case minimum of 20 for cost, it's 50% quality and 50% improvement activities. If you're a large practice and all four categories apply, it's 30% quality, 30% cost, 15% improvement activities, and 25% Promoting Interoperability. If you get the PI exception, it's 55% quality, 30% cost, and 15% improvement activities. And if you don't meet the case minimum of 20 for cost, it's what it is this year: 85% quality and 15% improvement activities.
Josie [37:18]: I love it. I'm sure the numbers are going through everyone's head right now. The next question we get a lot: how do you know if a patient is currently receiving RPM when you try to bill RTM for that patient, if it's a separately owned practice?
Rick Gawenda [37:43]: Great question, and the answer is you're not going to know. In my opinion only, with these codes out for almost 23 months, I'm sure a Medicare contractor has paid a physician's office for RPM and paid a physical therapy clinic for RTM on the same patient. I just don't know how CMS or the MACs are tracking that. The easier case to track would be a physician practice, where the physician bills RPM to the group NPI and TIN and the PT also has payment reassigned to the group. I could see how the MAC could catch that. I don't know how they'd catch a patient seeing Rick at Jake and Rick's Physical Therapy while also going to Kara's Occupational Therapy, with a different tax ID number, where Kara is doing RTM for the wrist while I'm doing RTM for the hip. If it's happening, I'm not sure it's getting caught, and if it is, I don't know how. But great question.
Josie [39:10]: Still some unknowns. One question that just came in the chat: does 98975 require data transmissions to be billed?
Rick Gawenda [39:25]: It does. CMS clarified that you need 16 days of data recording or transmission. I can't do the in-person evaluation on Josie today, have her download the Limber app, tell her what to do, and then, after 16 days pass without her doing anything, bill 98975. You need the 16 days of data recording and transmission. The AMA, which creates the CPT codes, says in the 2022, 2023, and 2024 CPT books not to report 98975, 98976, or 98977 for less than 16 days of monitoring.
Josie [40:20]: Thank you. Great question.
Rick Gawenda: Good question. I've been asked that one.
Josie: It came from an anonymous person in the chat.
Rick Gawenda: I always love the anonymous people.
Josie [40:36]: That concludes our questions unless anyone wants to drop more in the questions box. Thank you so much for tuning in, and thank you, Jake and Rick. It's great to see RTM scaling and the impact it's had on a lot of organizations. If you've already been doing RTM, we're glad to have you here, and if you're just getting started, we're glad to have you too as you learn about the changes going into 2024. Thanks again, Rick and Jake, for hosting and doing a great job summarizing all of this.
Rick Gawenda [41:13]: If you don't mind me saying one more thing: don't think of RTM as only a way to make money. Ask whether doing RTM will lead more patients to complete their plan of care. When people decide whether to do RTM, don't just look at what you'll get paid. What we're seeing is that only about 30% of patients complete their plan of care, and with RTM that number goes to 40, 44, 45%. Even among the 55% who don't complete the plan of care, instead of dropping off at visit four or five, they drop off at visit seven or eight. So not only do you get paid for RTM, you also get paid for more in-person visits because patients are coming for more visits. I want to make sure people don't look at RTM in a silo. It brings more people to you as well.
Jake Grundstein [42:26]: Love that, Rick. We're starting to see better outcomes from RTM too, so it's an exciting thing for the industry.
Rick Gawenda [42:33]: Better outcomes. Then you can go back to your insurance contracts and try to get more money, because you're getting people better in 9.1 or 9.2 visits when everybody else is averaging 11.8 or 12.2. We have to look at the big picture and not be a racehorse with blinders on.
Josie [42:51]: We did get another question, if you're open to answering one more.
Rick Gawenda [42:55]: Absolutely. I'm pumped up. I've got my soapbox.
Josie [43:00]: Medicare requires a 20% copay. Does that apply to the RTM CPT codes as well? Can you go into that a little?
Rick Gawenda [43:10]: With traditional Medicare, these codes are paid off the Medicare Physician Fee Schedule and are done under an outpatient PT, OT, or SLP plan of care. People think SLPs can't do this, but there are some codes SLPs can use for RTM as well. Medicare pays 80% of the allowed amount. If the patient has supplemental insurance, such as Medigap, it picks up the other 20%. If the patient has only Medicare, with no supplemental coverage and no Medicaid, the patient is responsible for the other 20%. That's the easy answer. For Medicare Advantage and commercial payers, whether it's a copay or coinsurance is up to the insurance company. I know Limber is working with these insurance companies to determine that, and to make sure RTM doesn't count against a therapy visit limit, because RTM is not a visit and it's not telehealth. If you're already with Limber, they can tell you which insurers are paying and how. If you're thinking about RTM and go with Limber, they'll help you with the insurers in your state.
Josie [44:39]: I'm glad you said that, because a common misconception is that RTM is a visit. We hear that all the time. There's another quick question about MIPS: what happens when a provider who is actively submitting MIPS leaves a practice?
Rick Gawenda [45:00]: Let me know if I answer this the way they meant. Say I worked at Jake's Physical Therapy in 2022, I was required to do MIPS in 2022, and either I didn't know or Jake didn't know, so we didn't do it. In 2024, on all my Medicare patients, I'll take a negative 9% payment adjustment. If I see a Medicare patient in 2024 and the allowed amount is $100, I get paid $91. Now say I leave Jake's private practice and go to Julia's Physical Therapy, another private practice, in 2024. That negative payment adjustment follows me to my next place of employment if it's a private practice. If I go to a facility that bills on the UB-04 claim form, such as a hospital outpatient department, rehab agency, or skilled nursing facility, it won't affect me, because those bill under the facility's NPI, not my personal NPI.
Just as a negative adjustment follows me, a positive adjustment does too. Say in 2022 I work at Jake's Physical Therapy, we do MIPS, I score 100 out of 100, and I get an 8.25% positive payment adjustment in 2024. If I go to work at Julia's practice in 2024, that positive 8.25% follows me there, so Julia gets a bonus by hiring me in this example.
Rick Gawenda [46:50]: The follow-up question I know you want to ask is how to ask about this in an interview. I'm not an HR person, so I don't know what you can and can't ask. But if someone is coming from a private practice to yours, you might want to figure out how to ask, "Did you participate in MIPS this year? Did you have to participate in MIPS?" A lot of times you'll get the deer-in-the-headlights look: "What's MIPS? I don't know." So how do you find that out?
Josie [47:37]: Thank you so much, and thanks for those last couple of questions. We'll be following up with a video recording of this webinar. Please don't hesitate to reach out to any of us. We're excited to move forward with all of this. Thank you again, and have a great rest of your day.
Starting in 2024, CMS allowed PTs and OTs in private practice to provide general supervision when their PTAs and OTAs furnished Remote Therapeutic Monitoring to Medicare beneficiaries, instead of the modified direct supervision required for in-person visits. Rick Gawenda noted that a state practice act requiring on-site supervision would still take precedence over Medicare.
No. The CY2024 proposed rule suggested it did, but the final rule released November 2, 2023 clarified that the 16-day data requirement did not apply to treatment management codes 98980 and 98981. In 2024 it still applied to 98975, 98976, and 98977. The CY2026 final rule later added codes for 2 to 15 days of data and 10 to 19 minutes of management.
No. CMS said multiple devices could be used, but the services associated with all devices could be billed by only one practitioner, once per patient, per 30-day period. APTA Private Practice, Limber, and other RTM vendors had argued that each discipline should be able to bill for its own work, and CMS did not agree.
Yes. CMS clarified that the restriction on RPM and RTM during a global period applied only to the practitioner who received the global surgical payment. Therapists did not perform the procedure and did not receive that payment, so they could furnish RTM during the global period whether they worked in the surgeon's practice or elsewhere.
CMS proposed raising it to 82 points but kept it at 75 points for the 2024 performance year, which affected 2026 payments. Rick Gawenda explained the tradeoff: it was easier to avoid a penalty, but CMS estimated the maximum positive adjustment for a perfect score would fall from about 8.82% to about 4.6%.
Yes, if the clinician moves to another private practice that bills under the clinician's individual NPI. A negative or positive adjustment follows that clinician. It does not apply when the clinician moves to a facility such as a hospital outpatient department, rehab agency, or skilled nursing facility, which bills on the UB-04 under the facility's NPI.
