CMS: RTM (Remote therapeutic monitoring) and Physical Therapy

arielcosta

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Our company is trying to distinguish what are the or are there even parameters to the meaning of "interactive communication with the patient/caregiver." Particularly for codes:
  • CPT code 989X4 — 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 989X5 — 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)
For example, if a therapist communicated with a patient/caregiver to monitor a musculoskeletal patient: throughout a month of treatment where that patient couldn't attend due to illness, or even the month after a patient "discharges" from therapy, would that apply as RTM and be billable...?

Would a PTA need to be directly supervised by a PT while performing the monitoring?

When RTM is billed, what is the place of service? Would it be office even though it is a "remote" service?
 
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