On November 1, 2022 the Centers for Medicare and Medicaid Services (CMS) issued the Calendar Year 2023 Final Rule for Services reimbursed under the Medicare Physician Fee Schedule.
This final rule addressed three issues raised in the proposed rule that had the potential to impact the future of Remote Therapeutic Monitoring (RTM).
Remote Therapeutic Monitoring or RTM allows providers to bill for the remote therapeutic management of their patients for musculoskeletal conditions using medical devices to collect non-physiological data. In January 2022, new CPT codes were introduced and Medicare began covering and paying for RTM services.
Examining the CMS Proposed Rule vs. Final Rule
- Proposed Rule: CMS proposed to create 4 new “G” codes to replace 98980 and 98981 to bill for RTM Treatment Management Services. Two G codes were created for physicians and non-physician practitioners and two other G codes were created for non physician healthcare professionals, such as PTs and OTs. CMS proposed significant payment cuts for RTM treatment management services provided by the non physician healthcare professionals, including PTs and OTs.
- Final Rule: The proposed G codes were withdrawn. All eligible providers including physicians, physical therapists and occupational therapists will continue to bill CPT codes 98980 and 98981 for the treatment management services and have the same reimbursement rates.
- Proposed Rule: In order to bill the treatment management codes (the 4 new “G” codes, GRTM 1-4), it was proposed that 98975 and 98976 or 98977 would have to be billed first and that at least 16 days of data must be reported.
- Final Rule: The proposed G codes were withdrawn and all providers eligible to bill RTM treatment management services are to continue to bill current CPT codes 98980 and 98981 which do not have the billing requirement in 2022.
- Proposed Rule: Proposed rule would have allowed physicians and non-physician practitioners to bill under general supervision and other non physician health care professionals use direct supervision. However, all providers are allowed to use “virtual presence” direct supervision through the last day of the calendar year in which the PHE ends. Under “virtual presence” supervision, PTs/OTs can be immediately available through virtual presence using real-time audio/video technology for RTM services.
- Final Rule: The final rule clearly states that providers can use the “virtual presence” rule at least through the end of 2023. In addition, CMS is allowing general supervision for all RTM services. Limber is seeking clarification from CMS to ensure PTs and OTs can also use general supervision in private practice settings for RTM services as the provision implies and whether this general supervision overrides the direct supervision requirement that is in place for regular therapy sessions.
Want to Learn More about the 2023 CMS Final Rule and RTM?
Have questions about RTM or understanding the impact of the CY 2023 Medicare Physician Fee Schedule? Join Limber Health’s Chief Medical Officer, Dr. Marc Gruner and Medicare billing and compliance expert, Rick Gawenda for a live webinar on Monday, November 21, 2022 as they discuss the 2023 regulations impacting RTM and how to properly implement RTM into your practice. Register HERE