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2024 Annual Update to the Therapy Code List: Remote Therapeutic Monitoring

CMS is updating Disposition 10, in addition to other modifications, to clarify that, for RTM services, physical and occupational therapists in private practice may provide general supervision of their therapy assistants when they don’t personally furnish the RTM services, beginning 1/1/2024.

Services delegated by therapists to therapy assistants are subject to the de minimis standard (except the device codes, CPT codes 98976 and 98977).

The five CPT® codes and long descriptors for RTM are:

  • CPT code 98975
    • Remote therapeutic monitoring (e.g., respiratory system status, musculoskeletal system status, therapy adherence, therapy response); initial set-up and patient education on use of equipment.
  • CPT code 98976
    • Remote therapeutic monitoring (e.g., respiratory system status, musculoskeletal system status, therapy adherence, therapy response); device(s) supply with scheduled (e.g., daily) recording(s) and/or programmed alert(s) transmission to monitor respiratory system, each 30 days.
  • CPT code 98977
    • Remote therapeutic monitoring (e.g., respiratory system status, musculoskeletal system status, therapy adherence, therapy response); device(s) supply with scheduled (e.g., daily) recording(s) and/or programmed alert(s) transmission to monitor musculoskeletal system, each 30 days.
  • CPT code 98980
    • Remote therapeutic monitoring treatment management services, physician/other qualified health care professional time in a calendar month requiring at least one interactive communication with the patient/caregiver during the calendar month; first 20 minutes.
  • CPT code 98981
    • Remote therapeutic monitoring treatment management services, physician/other qualified health care professional time in a calendar month requiring at least one interactive communication with the patient/caregiver during the calendar month; each additional 20 minutes (List separately in addition to code for primary procedure).

CMS designated the above CPT codes as “sometimes therapy” to permit physicians and certain NPPs, including nurse practitioners, physician assistants and clinical nurse specialists to furnish these services outside a therapy plan of care when appropriate. When furnished by therapists, these "sometimes therapy" services are “always therapy,” which means they must be accompanied by the appropriate therapy modifier (GP, GO or GN) to reflect that it is under a physical therapy, occupational therapy, or speech-language pathology plan of care, respectively.

More guidance on documentation requirements will become available from the professional organizations and NGS. Please ensure that you follow the guidelines from other payers as these codes may not be applicable or have other guidelines and requirements.

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Posted 1/22/2024