In 2022, the Centers for Medicare and Medicaid Services (CMS) introduced five new CPT codes for remote therapeutic monitoring (RTM), marking the introduction of patient-reported, nonphysiological data into coverage criteria. For 2023, CMS plans to further expand coverage to include a CPT code for cognitive behavioral therapy monitoring.
The emergence of RTM reimbursement marks an important milestone in the nascent digital therapeutics space, primarily due to the following reasons:
1) Validating the efficacy of telehealth:
The issuance of RTM CPT codes represents a validation of the enduring efficacy of digital care and telehealth solutions that began to gain significant traction during the public health emergency Covid-19, when in-person care was not a viable or safe option except for emergency applications.
While remote physiological monitoring (RPM) has been used in a variety of device-oriented applications for some time, reimbursement for RTM represents CMS’ confirmation of the utility and benefits of patient-reported, non-physiological data, specifically in respiratory and musculoskeletal care. skeletal system (MSK), where patient-reported information is increasingly included as an essential component and measure of successful and effective outcome.
Although confusion and challenges surrounding the nuances of RTM use and billing remain prevalent, increased reimbursement and the anticipated availability of expanded CMS guidance will encourage more providers to take advantage of these new CPT codes in the future.
The availability of digital enablement solutions that offer provider-prescribed digital care plans, population health management tools, patient status alerting and various other features beyond RTM enablement capabilities continues to grow. Strategically positioned vendors using such digital tools will be able to easily incorporate RTM into their workflows without additional burdens on FTE and administrators.
Additionally, it is likely that CMS will study the effectiveness and parameters of the current RTM CPT codes over the next several years. Ultimately, it is expected that CMS will further expand the use of reimbursable RTMs beyond respiratory and MSK care and include patient-reported information as a requirement for reimbursement for certain remote services. Since this is a nascent space, it’s safe to assume that CMS will also eventually consider whether other digital therapy solutions besides RTM may be eligible for expanded coverage.
2) Driving technology-enabled, optimized and cost-effective care:
Consistent with CMS’ ongoing efforts to promote optimized care to reduce the overall burden of healthcare costs, RTM CPT codes demonstrate a continued regulatory push toward adoption of enabling technologies that optimize care and reduce costs.
By moving the majority of patient care out of the clinic and into the home, RTM recovery can ease the workflow and recordkeeping burden on providers and care teams. This makes care more efficient while maintaining outcomes through high visibility of patient progress. Having more time for personal care also allows providers to target interventions to patients who need them most, increasing care outcomes for all patients.
It also allows care teams to increase full-time resources—an especially relevant benefit as health systems across the country continue to struggle with staffing challenges and burnout.
In addition, in addition to being a potentially lucrative new source of revenue for providers—whose payments continue to decline as CMS tightens value-based payment (VBP) margins—it will also drive nonoperative/conservative care as patient diagnoses will increasingly be managed on a global episodic basis.
3) Reducing barriers to care and promoting shared decision-making:
For rural, elderly, or low-income patients, personal care visits entail significant costs and challenges beyond just the cost of care. The costs of commuting to work, receiving family support, taking time off from work, or obtaining childcare can be prohibitive for many patient groups.
With a relatively small co-payment for RTM services, patients can alleviate the need for multiple in-person visits, enabling significant cost and time savings over the course of the treatment plan and facilitating cost-effective care for a larger patient population.
Additionally, given that RTM requires the patient’s ongoing commitment to the prescribed treatment plan, providers will strive to work with patients to ensure that they are adequately informed and that patient expectations and goals are based on a shared process of decision making. This allows providers to encourage high patient engagement and realistic goal setting, which is now a prerequisite for reimbursement and patient satisfaction.
With all that said, RTM cannot succeed in a vacuum. To ensure high engagement, strong outcomes, consistent reimbursement and increased patient satisfaction while maintaining care efficiency, reducing costs and avoiding unnecessary FTE burdens, providers will need to use a full suite of digital tools that automate RTM processes and integrate seamlessly into existing workflows and interoperability initiatives.
As CMS provides additional guidance on the nuances of RTM, and as digital stakeholders develop and deliver more effective RTM automation features, awareness of the benefits of RTM will drive adoption. Going forward, it will be important to closely monitor regulatory and payer developments around RTM coverage to ensure continued long-term adherence and consistent reimbursement.
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