The Centers for Medicare & Medicaid Services (CMS) in its ‘year 2022 annual update to the therapy code’ document introduced 5 newly added ‘sometimes therapy’ codes. CMS considers these 5 CPT codes to be remote therapeutic monitoring (RTM) services that physical therapists (PTs), occupational therapists (OTs), and speech-language pathologists can provide, when appropriate. CMS designated these CPT codes as ‘sometimes therapy’ to allow physicians and certain Non-physician Practitioners (NPPs), including nurse practitioners, physician assistants, and clinical nurse specialists to provide these services outside a therapy plan of care when appropriate. When therapists provide these ‘sometimes therapy’ services, they’re ‘always therapy.’ This means while billing Medicare, you must use the appropriate therapy modifier i.e., GP, GO, or GN to reflect that it’s under a physical therapy, occupational therapy, or speech-language pathology plan of care, respectively.
5 Newly Added Sometimes Therapy Codes
The ‘sometimes therapy’ codes and their long descriptors are as follows:
1. CPT 98975 code description
Remote therapeutic monitoring (e.g., respiratory system status, musculoskeletal system status, therapy adherence, therapy response); initial set-up and patient education on the use of equipment.
2. CPT 98976 code description
Remote therapeutic monitoring (e.g., respiratory system status, musculoskeletal system status, therapy adherence, therapy response); device(s) supply with scheduled (e.g., daily) recording(s) and/or programmed alert(s) transmission to monitor respiratory system, each 30 days.
3. CPT 98977 code description
Remote therapeutic monitoring (e.g., respiratory system status, musculoskeletal system status, therapy adherence, therapy response); device(s) supply with scheduled (e.g., daily) recording(s) and/or programmed alert(s) transmission to monitor musculoskeletal system, each 30 days.
4. CPT 98980 code description
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.
5. CPT 98981 code description
Remote therapeutic monitoring treatment management services, physician/other qualified healthcare professional time in a calendar month requiring at least one interactive communication with the patient/caregiver during the calendar month; each additional 20 minutes (List separately in addition to code for primary procedure).
The RTM treatment management services described by CPT codes 98980 and 98981 are provided remotely to patients in their homes by therapists in private practice (TPPs) and facility-based therapists. For example, therapists who work in rehabilitation agencies and comprehensive outpatient rehabilitation facilities would provide these services. You would do the RTM service for the initial set-up and patient education on the use of equipment (CPT code 98975) in the office or in the patient’s home.
Note that when physicians, NPPs, or therapists don’t directly perform the services, they must be done under direct supervision. While you must always provide therapists’ services under therapy plans of care, RTM services related to an RTM device that’s specific to therapy services, such as the ARIA Physical Therapy supply device in CPT code 98977 that includes therapeutic exercises, must also be provided under a therapy plan of care when provided by physicians and NPPs. If PTs and OTs delegate the RTM services to physical therapist assistants and occupational therapy assistants, respectively, they’re subject to the de minimis standard (with the exception of the 2 CPT codes for the RTM devices).
Medical Billers and Coders (MBC) is a leading medical billing company providing complete revenue cycle services. We hope this article will help you stay updated on therapy coding guidelines. If you need any assistance in therapy billing for your practices, email us at: info@medicalbillersandcoders.com or call us at: 888-357-3226.
CPT Copyright 2022: American Medical Association
Reference: MM12446 – 2022 Annual Update to the Therapy Code List
FAQs on CMS 2022 Therapy Code Update and Remote Therapeutic Monitoring (RTM)
In 2022, CMS introduced five new CPT codes for Remote Therapeutic Monitoring (RTM): 98975, 98976, 98977, 98980, and 98981. These codes cover various services like remote monitoring of respiratory and musculoskeletal systems, device setup, and management of therapy adherence and response.
RTM services can be provided by physical therapists (PTs), occupational therapists (OTs), and speech-language pathologists, as well as physicians and certain non-physician practitioners (NPPs) like nurse practitioners and physician assistants. However, when therapists provide these services, they must use appropriate therapy modifiers (GP, GO, GN) to indicate the therapy plan of care.
When billing RTM services under a therapy plan of care, you must use the following modifiers:
GP for physical therapy
GO for occupational therapy
GN for speech-language pathology
These modifiers ensure that Medicare recognizes the services as part of a therapy plan.
When physical therapy assistants or occupational therapy assistants provide RTM services, they are subject to the de minimis standard, except for the RTM device codes (CPT 98976 and 98977). This standard applies when services are delegated to assistants under the supervision of licensed therapists.
CPT codes 98980 and 98981 are used for remote therapeutic monitoring treatment management services. CPT 98980 covers the first 20 minutes of management services provided by a physician or qualified healthcare professional, while CPT 98981 covers each additional 20 minutes. These services must include at least one interactive communication with the patient or caregiver during the month.
