On November 2, 2023, the Centers for Medicare and Medicaid Services (CMS) released the 2024 Physician Fee Schedule (PFS) Final Rule. The annual rule announces rate updates and policy changes for Medicare payments under the PFS, effective on January 1, 2024.
Below are a few notable updates relevant to providers using Remote Therapeutic Monitoring (RTM) for musculoskeletal (MSK) services:
- General supervision of outpatient therapy services for Physical Therapists (PTs) and Occupational Therapists (OTs) in private practice: This is a very important provision that allows Physical Therapists and Occupational Therapists in private practice to provide general supervision for RTM services furnished by their PTAs and OTAs, respectively. This supports RTM management services to be performed outside of the clinic, which is instrumental to providing comprehensive at-home support for patients.
- 16-day data requirement does NOT apply to RTM treatment & management services: CMS officially clarified that the 16-day data requirement does NOT apply to RTM CPT codes 98980 or 98981.
- RTM coverage in RHCs and FQHCs: CMS finalized its proposal to include RTM with other care management services into HCPCs code G0511, a general care management services code for Rural Health Centers (RHCs) and Federally Qualified Health Centers (FQHCs). Expansion of RTM services to RHCs and FQHCs improves access to healthcare for underserved populations in remote areas, supports early intervention of conservative treatments, and promotes health equity.
- RTM coverage during Surgical Global Periods: CMS clarified that the policy that prohibits RTM services being furnished during the global period only applies to billing practitioners, who are receiving the global service payment. Practitioners, such as therapists, who are not receiving the global service payment because they did not furnish the global procedure, would be permitted to furnish RTM services during a global period.
Please note: This blog is for informational purposes only, does not constitute billing or legal advice, and includes a review of information about the 2024 CMS Final Rule, which is publicly available.