Ophthalmology and Optometry Coding Alert

Question: We read about new remote therapeutic monitoring codes coming out. Can you tell us what this means?

Alaska Subscriber

Answer: You are correct — beginning January 1, you’ll be able to code various RTM services using the following codes:

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

Basically, the “RTM codes monitor health conditions, including musculoskeletal system status, respiratory system status, therapy (medication) adherence, and therapy (medication) response,” according to the 2022 MPFS proposed rule. In other words, RTM services go beyond data collection to measure the efficacy of a given treatment on a patient’s condition. Additionally, the RTM codes allow non-physiologic data to be collected. Data also can also be self-reported as well as digitally uploaded.

To do that, the patient must use a device that meets the Food and Drug Administration (FDA) definition of a medical device as described in section 201(h) of the Federal Food, Drug and Cosmetic Act (FFDCA), the proposed rule notes. This does not mean that the device has to be approved by the FDA. But it does mean the device has to be “recognized in the official National Formulary, or the United States Pharmacopeia, or any supplement to them” (Source: www.fda.gov/regulatory-information/search-fda-guidance-documents/classification-products-drugs-and-devices-and-additional-product-classification-issues).

Important reminder: Medicare’s current thinking regarding the RTM services suggests they should only be performed incident to with direct physician supervision. Further, according to the proposed rule, CMS believes the current construct of the RTM codes disallows physical therapists and other practitioners who are not physicians or NPPs from reporting the RTM codes, because CMS views the codes as including “incident to” services, and only physicians and certain other practitioners are authorized to furnish and bill “incident to” services under Medicare rules.

This could change when the proposed rule becomes finalized later this year. Stay tuned to Ophthalmology and Optometry Coding Alert for more details.