CMS Proposes New Remote Therapeutic Monitoring (RTM) Codes

CMS Proposes New Remote Therapeutic  Monitoring (RTM) Codes

BreatheSuite is thrilled about a new category of remote monitoring CPT codes proposed by the CMS - Remote Therapeutic Monitoring (RTM). The new codes are part of the 2022 Medicare Physician Fee Schedule (MPFS) and are intended to expand the scope and reach of remote monitoring to reimburse the monitoring of non-physiological data. This development has the potential to positively impact the lives of millions of respiratory patients across the US.


What are the codes?

  • CPT code 989X1 — 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 989X2 — Remote therapeutic monitoring; 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 989X3 — Remote therapeutic monitoring ; 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 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


Why does this matter?

These codes will enable reimbursement for new RTM devices and data collection in comparison to typical Remote Patient Monitoring (RPM) devices that are only centred around physiological parameters. Devices like the BreatheSuite MDI, will be able to be billed in both the provider and non-provider settings. It is estimated that reimbursement for the RTM codes will be delivered at the same rates as the RPM codes. Only certain types of disease monitoring devices (respiratory and musculoskeletal) are eligible for these new codes under the 2022 Medicare Physician Fee Schedule. 


Why RTM?

Remote Therapeutic Monitoring opens up an opportunity for respiratory health providers to get reimbursement using a passive monitoring system like inhaler sensors instead of non-passive measurements like spirometry or pulse oximetry.


Billing for Remote Therapeutic Monitoring*

The new RTM codes can be divided into 2 categories - service codes & timed-based RTM management codes.


RTM Service Codes: 989X1, 989X2 and 989X3

RTM service codes reimburse for expenses associated with establishing RTM services, including initial set-up and patient education on use of equipment, and the transmission of the data used to monitor the respiratory system.

  • CPT code 989X1 — is used to report the setup and patient education on RTM and use of the device. As such, this code is billed once per patient on the initiation of the RTM service (2020 RPM avg pay rate:~$21)
  • CPT code 989X2 — is the monthly code that reimburses for the supply of the device and monitoring of the patient data


RTM Management  Codes: 989X4 and 989X5

RTM management codes are monthly time-based codes that cover the interactive communication of the physician or other qualified healthcare professional with the patient or caregiver to manage treatment.

  • CPT code 989X4 - The first 20 minutes of logged time each month is billed to this code (2020 RPM avg pay rate: ~$55)
  • CPT code 989X5 - Additional 20 minutes of logged time each month is billed to this code (2020 RPM avg pay rate: ~$44, can be billed twice per month)

Sample RTM Billing:
An example of RTM Billing


You still have time to send feedback on the 2022 Medicare Physician Fee Schedule proposed rule. The deadline to submit feedback is  5:00 p.m. ET on Sept. 13, 2021. You can submit your comments here. When commenting, refer to file code CMS-1751-P in your submission. You may also send your comments by mail to:

  • Regular Mail: Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS-1751-P, P.O. Box 8016, Baltimore, MD 21244-8016.
  • Express Overnight Mail: Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS-1751-P, Mail Stop C4-26-05, 7500 Security Boulevard, Baltimore, MD 21244-1850


Why BreatheSuite?

BreatheSuite is uniquely positioned with an inhaler adherence and inhaler technique tracking device that will allow you to start billing for these RTM codes as soon as they come into effect.  If remote monitoring of respiratory patients (ex. COPD & Asthma patients) is currently a service you offer, or if it is a service that you would like to offer in 2022, now is the time to act. BreatheSuite will be working with a limited number of partners starting in 2022 to equip them with a remote therapeutic monitoring solution - meet with us to discuss the opportunity now!


Disclaimer: The reimbursement information is being provided on an “as is” basis with no express or implied warranty of any kind and should be used solely for your internal informational purposes only. The information does not constitute professional or legal advice on reimbursement and should be used at your sole liability and discretion. All coding, coverage policies and reimbursement information are subject to change. Before filing any claims, it is the provider’s sole responsibility to verify current requirements and policies with the applicable payer.

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