Newly Proposed CPT Billing Codes for Behavioral Remote Therapeutic Monitoring (RTM)

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HERE IS HOW

Over the years, the Center for Medicare and Medicaid Services (CMS) has approved reimbursement codes for RPM by physicians and non-physician practitioners (NPP) who used E/M codes for billing. Such CPT billing codes excluded reimbursement for non-physician qualified health care professionals(QHPs), which include most behavioral professionals who are unaffiliated with medical offices.

This year, CMS is suggesting that two new remote therapeutic monitoring (RTM) codes be approved for QHPs who do not work under the direct supervision of physicians, including clinical psychologists and clinical social workers. If another part of the new CMS proposal is approved, this definition may be extended to counselors, who have been allowed reimbursement only for working under the direct supervision of a  physician’s office.

Remote Patient Monitoring vs. Remote Therapeutic Monitoring Definitions

Before discussing proposed remote patient monitoring (RPM) codes, definitions are warranted. RPM involves digital technology to capture and analyze patients’ physiological data, such as blood pressure, glucose levels, and lung function. In contrast, remote therapeutic monitoring (RTM) focuses on non-physiological data to track wellness and manage chronic conditions, such as musculoskeletal system status, respiratory system status, therapy (medication) adherence, therapy (medication) response, and pain.

Proposed CPT Billing Codes for Remote Therapeutic Monitoring

If approved, the newly proposed CMS rule recently published in the proposed 2023 Physician’s Fee schedule would include these two new codes of relevance to behavioral providers who are QHPs:

• HCPCS code GRTM3. Remote therapeutic monitoring treatment assessment services, first 20 minutes furnished personally/directly by a non–physician qualified health care professional over a calendar month. Requires at least one interactive communication with the patient/caregiver during the month.
• HCPCS code GRTM4  Remote therapeutic monitoring treatment assessment services, additional 20 minutes furnished personally/directly by a non–physician qualified health care professional over a calendar month. Requires at least one interactive communication with the patient/caregiver during the calendar month. The (List separately in addition to code for primary procedure).

CMS has proposed an amendment to change the required supervision of QHP from direct to general supervision. This looser term means that the physician doesn’t have to be in the same building when the service is provided as required by direct supervision. Instead, the physician can now use remote devices to supervise the QHP staff. This change will broaden the scope of remote therapeutic business models currently managed by physicians. The proposed HCPCS codes for such services will fall under GRTM1 and GRTM2.

Remote Therapeutic Monitoring for Cognitive Behavior Therapy

The 2023 proposed Physician Fee Schedule also initiates a new RTM device code for cognitive behavioral therapy (CBT), based on the American Medical Association’s CPT code of 989×6 to bill for CBT devices. Value and payment will be established at the discretion of each local Medicare Administrative Contractor (MAC) and could vary nationally. The wording of the proposed rule currently includes:

Remote therapeutic monitoring (e.g., therapy adherence, therapy response); device(s) supply with scheduled (e.g., daily) recording(s) and/or programmed alert(s) transmission to monitor cognitive behavioral therapy, each 30 days).

Stakeholder Comments about Remote Therapeutic Monitoring

CMS has invited comments and input on these and other Physician Fee Schedule proposals from all stakeholders before September 6 at 5 PM ET. Send surface mail to: Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS-1770-P, PO Box 8016, Baltimore, MD 21244-8016. Also, express overnight mail can be sent to Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS-1770-P, Mail Stop C4-26-05, 7500 Security Boulevard, Baltimore, MD 21244-1850

PLEASE NOTE: The above-described CPT billing codes are proposed by CMS but not yet approved. Do not use the4 CPT codes until official approvals are announced.

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