Top 5 Rules for RPM and RTM in Therapy Practices

The healthcare landscape is evolving, and remote monitoring services are gaining traction. The Centers for Medicare & Medicaid Services (CMS) has introduced significant changes to Remote Patient Monitoring (RPM) and Remote Therapeutic Monitoring (RTM) services in the 2024 Final Rule.

These updates aim to improve patient access, enhance care coordination, and streamline billing processes. For therapists and healthcare practitioners, understanding these new guidelines is crucial to stay compliant, maximize reimbursements, and provide high-quality remote care.

This blog post delves into the top five rules for RPM and RTM in 2024, highlighting their impact on various therapy practices. Stay ahead of the curve and equip yourself with the knowledge to navigate these changes seamlessly.

Understanding RPM and RTM

What is Remote Physiologic Monitoring (RPM)

RPM involves the collection and transmission of a patient’s physiological data, such as weight, blood pressure, blood glucose levels, or other vital signs, from a remote location to a healthcare provider for evaluation and monitoring. RPM enables healthcare providers to track and manage patients’ chronic conditions without requiring in-person visits, promoting better disease management and potentially reducing hospitalizations.

What is Remote Therapeutic Monitoring (RTM)

RTM is a relatively new service introduced by CMS in 2022. It involves the remote monitoring of a patient’s musculoskeletal system or respiratory system status using devices approved for therapeutic purposes.

RTM allows healthcare providers, such as physical therapists, occupational therapists, and respiratory therapists, to monitor and manage patients’ therapy adherence, progress, and outcomes remotely. This can facilitate more efficient and targeted treatment plans, particularly for patients with musculoskeletal or respiratory conditions.

Both RPM and RTM services aim to improve patient care, increase access to healthcare services, and potentially reduce healthcare costs by enabling remote monitoring and management of patients’ conditions without the need for frequent in-person visits.

Top 5 Rules for RPM and RTM

Patient Relationship Requirements for RPM and RTM

Previous Rule: RPM services could only be provided to patients with an established relationship with the billing provider or a member of the same group practice, involving an in-person visit within the last 6 months.

2024 Final Rule Change: The timeframe for an in-person visit to establish the patient-provider relationship has been extended to 12 months for RPM services.

Impact on Therapy Practices:

This change provides more flexibility for therapy practices, as they can now offer RPM services to patients whose last in-person visit was within the past 12 months, instead of the previous 6-month window. This is particularly beneficial for practices that provide long-term care or manage chronic conditions, such as occupational therapy for individuals with disabilities, speech therapy for patients with communication disorders, or mental health therapy for those with ongoing mental health conditions.

RTM Does Not Contain an “Established Patient” Requirement

Previous Rule: RTM services were a new category introduced in 2022, with limited guidance initially provided.

2024 Final Rule Change: The 2024 Final Rule clarifies that there is no “established patient” requirement for RTM services, allowing providers to offer these services to new patients without an existing in-person visit.

Impact on Therapy Practices: 

The absence of an “established patient” requirement for RTM services is particularly beneficial for therapy practices that provide remote therapeutic monitoring, such as physical therapy, occupational therapy, or respiratory therapy. Practices can now offer RTM services to new patients without the need for an initial in-person visit, increasing access to care and potentially attracting new clients.

Practitioners Must Collect at Least 16 Days of Data Per 30-Day Period

Previous Rule: The requirement for the minimum number of data collection days was not explicitly specified.

2024 Final Rule Change: The 2024 Final Rule mandates that practitioners must collect at least 16 days of data per 30-day period for both RPM and RTM services to qualify for reimbursement.

Impact on Therapy Practices: 

This rule ensures that therapy practices providing RPM or RTM services actively monitor and collect data from their patients throughout the month. Practices offering services such as applied behavior analysis, speech therapy, occupational therapy, pediatric therapy, or mental health therapy may need to adjust their data collection protocols to meet this minimum requirement, potentially increasing the workload for practitioners and support staff.

Only One Practitioner Can Bill Medicare for RPM/RTM Services

Previous Rule: The guidelines for billing multiple practitioners for RPM/RTM services were not clearly defined.

2024 Final Rule Change: The 2024 Final Rule clarifies that only one practitioner can bill Medicare for RPM or RTM services provided to a patient during a 30-day period.

Impact on Therapy Practices: 

This rule may impact therapy practices that involve multiple providers or disciplines in a patient’s care. For example, if a patient receives occupational therapy, speech therapy, and mental health therapy simultaneously, the practice will need to determine which provider will submit the RPM or RTM claims for that patient during a given 30-day period. Coordination and clear communication among providers will be essential to ensure compliance with this rule.

Use of RPM/RTM with Other Services

Previous Rule: Guidance on using RPM/RTM services in conjunction with other services was limited.

2024 Final Rule Change: The 2024 Final Rule provides more clarity on how RPM and RTM services can be billed alongside other services, such as Evaluation and Management (E/M) visits, care management services, and other non-face-to-face services.

Impact on Therapy Practices: 

This guidance is beneficial for therapy practices that offer a range of services in addition to RPM or RTM. For instance, a practice providing occupational therapy, speech therapy, and mental health services may be able to bill for RPM or RTM services along with appropriate E/M codes or care management services, depending on the specific circumstances. However, practices must carefully review the guidelines to ensure they are billing correctly and not duplicating services.

To conclude, navigating the ever-evolving landscape of Medicare’s Remote Patient Monitoring (RPM) and Remote Therapeutic Monitoring (RTM) services requires staying up-to-date with the latest guidelines.

By understanding and adhering to the top five rules outlined in this blog post, therapy practices can ensure compliance, optimize reimbursements, and provide high-quality remote care to their patients.

As the healthcare industry continues to embrace remote monitoring technologies, staying informed and adapting to these changes will be crucial for sustained success and growth in the field of therapy services.