Discover the Remote Therapeutic Monitoring (RTM) Changes in the 2024 CMS Final Rule

TL;DR

In its 2024 Medicare Physician Fee Schedule (PFS) Final Rule, the Centers for Medicare and Medicaid Services (CMS) added ‘Clarifications for Remote Monitoring Services’. These are: easier billing for PTs and OTs; reducing the risk of confusion by only one practitioner being able to bill in a 30-day period; changes to the 16-day data rule for supply codes 98980 and 98981; changes to billing options for those who did not receive a global service payment, clarifying that those who received a global service payment cannot bill RTM within 90 days of surgery; better coverage for Rural Health Centers (RHCs) and Federally Qualified Health Centers (FQHCs); the ability to bill for RTM alongside other services. The moveUP app provides an easy-to-use software for RTM usage both for patients and providers.

Introduction

RTM services utilize technology to connect healthcare providers with patients without the need for physical appointments. It allows for real-time monitoring of care pathways and non-physiologic data, such as medication, lifestyle habits, musculoskeletal system status, and physiotherapy, which in turn enables the healthcare provider to update plans to suit progression or needs quickly and efficiently. RTM aims to enhance patient care by providing real-time data to healthcare professionals, allowing for more proactive and personalized interventions.

Although relatively new and only becoming billable in the 2022 CMS final rule, we have already seen improved patient outcomes, experience, and medication adherence. And the more data a patient shares via RTM, the easier it is to adjust treatment plans.

Motivating patients can be challenging, as physiotherapy can be uncomfortable and difficult, but RTM helps keep them on track with their recovery goals. By removing obstacles and communicating regularly about treatment plans, patients will engage better with their treatment and thus be more likely to complete the course.

Using RTM also allows you, as the healthcare provider, to:

·       Automate care pathways – easing the burden on staff and saving time;

·       Fill in cancellations – if a patient cancels, RTM allows you to fill in that hour with billable work, if you choose to;

·       Reach inaccessible or immobile patients who may struggle to travel to the office due to pain or lack of transport, live in rural locations, or simply cannot align their work schedule;

Focus your physical therapist assistants (PTAs) and occupational therapy assistants (OTAs) on RTM tasks, supporting the education of patients on the software or monitoring patient activity. In response to increased comments on proposed rules relating to RTM, the Centers for Medicare and Medicaid Services (CMS) in the US added a section entitled ‘Clarifications for Remote Monitoring Services’ in its 2024 Medicare Physician Fee Schedule (PFS) Final Rule, which came into effect on 1 January 2024.  

The following blog will explore the proposed rules and the implications for those working in Ambulatory Surgery Centers (ASCs) and Physical Therapy (PT) clinics. This will help you to understand how the changes will have a positive impact, including the financial implications, the effect on your day-to-day running of facilities and how you can give the highest quality of patient care going forward using the moveUP app.

What has been proposed, and what does it mean for your work?

The CMS Final Rule has noted its key clarifications: easier at-home support for patients, increased flexibility and streamlining with regard to billing, adapted global service payments, and better coverage in rural populations.

Read the clarifications below:

1. Billing for RTM:

The first detail, and one that is very important, relates to the general supervision of outpatient therapy services for Physical Therapists (PTs) and Occupational Therapists (OTs) in private practice. This allows you to provide general supervision for RTM services, allowing for at-home support for patients without the requirement of an established patient relationship (for the time being). However, the CMS suggested that RTM should be utilized after establishing a treatment plan.

Also, if you are a PT or OT, you can now bill Medicare for RTM services – as can your assistants – which facilitates broader access to RTM services within private practice settings, and only one practitioner can bill RTM services for a patient in a 30-day period, even with multiple medical devices. This will help avoid any confusion and avoid the risk of overlapping claims, which will streamline the whole billing process and ensure only one person is responsible for the coordination of a patient’s RTM. By allowing different team members more billing capabilities, it enhances collaboration and shows how important it is for PTs and OTs to deliver RTM services as well as those working in ASCs.

Additionally, practitioners can bill Medicare for RTM concurrently within certain care management services, which saves time and ensures more personalized care for all patient needs.

2. The 16/30-day data requirement:

The CMS has clarified that the treatment monitoring codes 98980 and 98981 do not need to adhere to the current 16-day data requirement – meaning providers should record at least 16 days of date in any 30-day period – which gives healthcare providers greater flexibility and makes it easier to understand the expectations of the different remote monitoring codes, tackling any concerns that had arisen due to the requirement previously covering all codes. However, the supply code 98977 is still part of the 16/30 rule.

3. RTM Coverage During Surgical Global Periods:

If you or your colleagues receive a global service payment during global surgery periods, you are prohibited from billing Medicare for RTM for the same condition for the same payment, but you may do so for a separate condition that is not linked to the global procedure/service.

However, if you did not receive a global service payment (for instance, you are a PT), you may provide RTM for the same patient with the same condition during the global period. This should help balance any financial considerations, adapting billing strategies based on patient care plans, therefore allowing for more flexibility in care and more personalisation.

4. RTM coverage in Rural Health Centres and Federally Qualified Health Centers

Now, Rural Health Centers (RHCs) and Federally Qualified Health Centers (FQHCs) can bill Medicare separately for RTM services, receiving their own general care management service codes. This addresses the challenges RHCs and FQHCs face, offering better financial flexibility, more control over services and will improve healthcare access for populations that are less served, encouraging earlier intervention and more health equity in those areas for those in need of RTM services.

5. RTM and other services

Finally, RTM can still be billed alongside Chronic Care Management (CCM), Transitional Care Management (TCM), Behavioral Health Integration (BHI), Principal Care Management (PCM), and Chronic Pain Management (CPM) services as long as no double billing occurs.

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Greater flexibility, better billing

As an RTM provider, the Medicare Final Rule 2024 clarifications will make working with the services much easier, specifically when it comes to billing – now, it is more specified and therefore streamlined, reducing the risk of mistakes. It also facilitates collaboration and demonstrates the vital role various team members play in PT clinics and ASCs in particular.

By simplifying the system, it should encourage more healthcare providers to utilize RTM services and gain the benefits digitized healthcare care provide – greater personalization, more engaged patients, more effective treatment, and cost reduction.

Why choose moveUP?

moveUP is a clinically proven cloud-based solution for orthopedics for patient engagement, healthcare, insights, and care team collaboration. You can connect in real-time via the patient phone app or surgeon/PT web app, allowing for better and more personalized treatment programs through regular updates, completely remotely.

Patients can:

·       Record daily steps through integration with wearable devices and health tracking apps;

·       Share daily updates on progress with their care team;

·       Access all their daily exercise videos (with clear instructions);

·       Find resources to allow for more proactive recovery and knowledge;

·       Directly message their physician with updates on symptoms, upload scar photos, ask for advice and allow for regular adaptions.
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Medical professionals can:

·       Monitor and personalize treatment (update exercises daily) in one or two clicks;

·       Plan exercises ahead of time;

·       Easily export what they can bill, based on interactions with the patient and patient compliance - this can be sent directly to Medicare;

·       Engage with patients through goal settings, progress visualization, and to improve adherence, satisfaction and retention;

·       Identify and filter patients that need additional support or care;

·       Automate PROMs and PREMs collection through surveys and assessments to reduce administrative burden;

·       Track progress through tables and graphs that summarize essential information including pain levels, medication, quality of life and activity;

·       Compare progress with other patients using the moveUP app;

·       And more.

Success story

Australian Dr I. Nizam utilized the app, getting 42 registrations over the April-September 2023 period:

·       more than half adhered to PROMS,

·       74% filled in the daily questionnaires,

·       66% sent video requests,

·       And around three quarters of users found the application easy to use.

Dr Nizam found there was better patient engagement and preparation for surgery, and the insights it offered were powerful for marketing, clinical and quality control.

So why not use us for your RTM needs and save yourself time and money, and provide better care for your patients? Learn more.

Explore our RTM revenue calculator to discover the potential additional earnings you can generate.