Who May Bill for RTM Services?

A ‘physician or other qualified health care professional’ is an individual who is qualified by education, training, licensure/regulation (when applicable) and facility privileging (when applicable) who performs a professional service within his/her scope of practice and independently reports that professional service.

May Office Staff Provide RTM Services?

Beginning January 1, 2023, physicians and certain non-physician practitioners (e.g., PAs and NPs) may bill for services furnished by clinical staff under general supervision, provided that the other requirements for "incident to" services are met. However, for other qualified health care practitioners (e.g., CSWs, CRNAs, PTs, OTs, SLPs), RTM services must be personally furnished by the billing qualified health care practitioner or, in the case of a PT or OT, by a therapy assistant under the PT’s or OT’s supervision.

What are the Documentation Requirements for RTM Services?

We recommend that the RTM services be documented just like other time-based services are documented, such as office visits. Be prepared for comparison to coding guidelines and whether time-based codes have appropriate documentation showing time spent in an interactive communication with the patient and whether the requisite level of decision-making is apparent in the provider’s medical records. Auditors may look for the following documentation in the patient’s medical record, i.e., date, start and end time, treatment plan and care plan.

Is There a Limit on Reporting RTM Services?

Coverage of RTM services is just now being established. There are currently no guidelines published on the time period for RTM services (e.g., 6 months, 1 year). Medical necessity is the determining criteria. Each patient is different, and some may require RTM services longer than others.

Patient Financial Responsibility

Patient deductibles/co-insurance/co-payments will apply to remote monitoring services based on individual health plan parameters. Deductibles must be met annually. The timing of RTM services relative to total knee arthroplasty, other surgical procedures and/or other services will impact the total patient financial responsibility amount for RTM services. Medicare beneficiaries should expect a coinsurance amount after their annual Part B deductible has been met. Many Medicare beneficiaries also purchase supplemental insurance which may help cover these expenses. Medicare Advantage plan members will likely have a small co-payment associated with RTM services.

Are patients able to be reimbursed for the cost of Apple Watch?

The patient may be able to submit the cost of the Apple Watch as a potentially reimbursable expense to their Health Savings Account (HSA)/Flexible Spending Account (FSA). When seeking HSA/FSA reimbursement for personal use items, it must be demonstrated the item is being used primarily for the treatment of a medical condition. 91��Ƭ�� has drafted a cover letter and letter of medical necessity to assist with the process of seeking reimbursement of the Apple Watch through these accounts: Apple Watch HSA/FSA Cover Letter Apple Watch Letter of Medical Necessity For additional guidance and/or questions regarding reimbursement eligibility or claims submission, please contact your FSA/HSA plan administrator.

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Remote Therapeutic Monitoring (RTM) FAQs

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This website and the material contained herein are intended for informational purposes only. Nothing herein is advice, legal advice or a recommendation of any kind, and it should not be considered as such. The content of this website was obtained from the third-party sources cited within and is subject to change without notice, resulting from changes in reimbursement laws, regulations, rules and policies. All content is informational only, general in nature, and does not cover all situations or all payers' rules or policies. The content is not intended to apply to any particular situation. In all cases, the service and the product must be reasonable and necessary for the care of the patient to support reimbursement. Providers should report the procedure and related codes that most accurately describe the patients' medical condition, procedures performed and the products used. The information on this website represents no promise or guarantee by 91��Ƭ�� regarding coverage or payment for products or procedures by Medicare or other payers. This website may not be used as an official source of information. Providers should check Medicare bulletins, manuals, program memoranda, Medicare guidelines and other payer information to ensure compliance with Medicare and other payer requirements.��Inquiries may be directed to the Part A/B Medicare Administrative Contractor, or to appropriate payers. 91��Ƭ�� specifically disclaims liability or responsibility for the results or consequences of any actions taken in reliance on information in this website.

All content herein is protected by copyright, trademarks and other intellectual property rights, as applicable, owned by or licensed to 91��Ƭ�� or its affiliates unless otherwise indicated, and must not be redistributed, duplicated or disclosed, in whole or in part, without the express written consent of 91��Ƭ��.��

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91��Ƭ��

Remote Therapeutic Monitoring (RTM) FAQs

Source:
MA definition of a Qualified Health Care Professional (QHP), 2013

Source:

Source:
https://validic.com/your-guide-to-reimbursement-for-remote-patient-monitoring/

Source:��
Section 1862(a)(1)(A) of the Social Security Act

Source: ��
CY 2022 Medicare Physician Fee Schedule, Final Rule.��Federal Register, November 19, 2021. Medicare Part B Monthly Actuarial Rates, Premium Rates, and Annual Deductible Beginning January 1, 2022,��Federal Register, November 17, 2021.

Sources:

https://fsastore.com/articles/learn-need-letter-medical-necessity.html

Legal Disclaimer

91��Ƭ��

Remote Therapeutic Monitoring (RTM) FAQs

Who May Bill for RTM Services?

Source: MA definition of a Qualified Health Care Professional (QHP), 2013

May Office Staff Provide RTM Services?

Source:

What are the Documentation Requirements for RTM Services?

Source: https://validic.com/your-guide-to-reimbursement-for-remote-patient-monitoring/

Is There a Limit on Reporting RTM Services?

Source:�� Section 1862(a)(1)(A) of the Social Security Act

Patient Financial Responsibility

Source: �� CY 2022 Medicare Physician Fee Schedule, Final Rule.��Federal Register, November 19, 2021. Medicare Part B Monthly Actuarial Rates, Premium Rates, and Annual Deductible Beginning January 1, 2022,��Federal Register, November 17, 2021.

Are patients able to be reimbursed for the cost of Apple Watch?

Sources: https://fsastore.com/articles/learn-need-letter-medical-necessity.html

Legal Disclaimer

Source:
MA definition of a Qualified Health Care Professional (QHP), 2013

Source:
https://validic.com/your-guide-to-reimbursement-for-remote-patient-monitoring/

Source:��
Section 1862(a)(1)(A) of the Social Security Act

Source: ��
CY 2022 Medicare Physician Fee Schedule, Final Rule.��Federal Register, November 19, 2021. Medicare Part B Monthly Actuarial Rates, Premium Rates, and Annual Deductible Beginning January 1, 2022,��Federal Register, November 17, 2021.

Sources:

https://fsastore.com/articles/learn-need-letter-medical-necessity.html