On October 18, 2024, the American Medical Association’s (AMA’s) Current Procedural Terminology (CPT) Editorial Panel released a Summary of Panel Actions from its September 2024 Panel Meeting, which includes six new remote physiologic monitoring (RPM) and remote therapeutic monitoring (RTM) codes in addition to revisions to the existing codes. Effective January 2026, these changes include removing the current requirement for healthcare providers to receive 16 days’ worth of data to bill RPM codes. The AMA CPT Editorial Panel likely made these updates in response to stakeholder feedback that the 16-day billing threshold was not necessary in certain clinical use cases. Additionally, two new codes will reimburse providers for 10-19 minutes of managing RPM or RTM data in a month.  

Background

Remote patient monitoring, including RPM and RTM, is a form of Medicare reimbursed virtual care that allows providers to remotely monitor and manage their patients’ acute and chronic conditions. RPM involves the use of technology to remotely monitor and analyze patients’ physiological metrics (e.g. oxygen saturation, blood pressure, blood sugar) while RTM involves the use of technology to remotely capture patients’ non-physiologic data related to patients’ musculoskeletal or respiratory system, including treatment adherence. RTM data, unlike RPM, can be self-reported by a patient. Currently, both RPM and RTM reimbursement codes require that data is collected for at least 16 days in a 30-day period.

Current Procedural Terminology codes are a standardized set of codes used by healthcare providers to describe medical services and procedures, which undergo continuous updates through a process lead by AMA’s CPT Editorial Panel. There are currently five codes for which CMS reimburses RPM services: CPT® codes 99091, 99453, 99454, 99457 and 99458. These include two practice-expense-only codes (99453 and 99454) and three codes for treatment management and ongoing monitoring services (99091, 99457 and 99458). RTM codes include the following: CPT® codes 98975, 98976, 98977, 98980, and 98981. RPM/RTM codes are valued by the AMA Relative Value Scale Update Committee (RUC), which works to determine the reimbursement rates associated with the CPT codes used for billing RPM/RTM services. Additional information on RPM/RTM billing and reimbursement policies are available here.

There has been a recent scrutiny on fraud and abuse issues related to Medicare reimbursement of RPM/RTM services. A report from the Department of Health and Human Services (HHS) Office of Inspector General (OIG) found potential fraud in RPM/RTM billings and urged additional oversight. OIG found that 28 percent of enrollees in RPM programs never had a claim or encounter record for the education or set up of RPM devices; 23 percent never had a claim or encounter record for the supply of an RPM device; and 12 percent did not receive treatment management services. According to the OIG report, CMS concurs with OIG’s recommendations to set additional safeguards, educate providers on RPM billing, and monitor companies specializing in RPM.

Updates to CPT and RPM Codes

The AMA’s Summary of Panel Actions outlines the following new RPM/RTM codes.

CPT CodeSummary
99XX4Supply code for remote physiologic monitoring devices when only 2-15 days’ worth of data are collected in a month.
98XX4Supply code for remote respiratory monitoring when only 2 – 15 days’ worth of data are collected in a month.
98XX5Supply code for remote musculoskeletal monitoring when only 2 – 15 days’ worth of data are collected in a month.
98XX6Supply code for remote cognitive behavioral therapy monitoring when only 2 – 15 days’ worth of data are collected in a month.
99XX5Code for the first 10-19 minutes a provider spends managing remote physiologic monitoring data in a month.
98XX7Code for the first 10-19 minutes a provider spends managing remote therapeutic monitoring data in a month.

As mentioned above, these new changes effectively eliminate the 16-day data transmission and collection threshold for providers to bill RPM and RTM codes. Specifically, this requirement applied to CPT codes 99454 (RPM), 98976 (RTM (respiratory)), and 98977 (RTM (musculoskeletal)).

Four new RPM supply codes may enable providers to use RPM devices to monitor acute and chronic conditions. Providers had previously argued that a 16-day reporting requirement limits RPM’s applicability to chronic conditions. Two new CPT codes for RPM management would aid providers in using RPM for acute conditions by requiring only 10-19 minutes of device management a month.

Takeaways

The AMA’s RUC will reconsider valuation for these codes in January 2025. Their valuation will most likely not be known until CMS publishes its proposed 2026 Physician Fee Schedule next summer. Stakeholders should continue to monitor additional developments from the AMA and CMS related to RPM/RTM CPT codes.

With the development of digital health tools, many patients and providers have chosen to use these tools to support clinical care. However, federal reimbursement policies have posed financial obstacles for some providers. These recent policy changes may make RPM services more accessible and financially viable for providers, potentially leading to increased adoption of these tools.

For more information on how these updates impact your organization, please contact the professionals listed below, or your regular Crowell Health Solutions contact.

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Photo of Troy A. Barsky Troy A. Barsky

Troy Barsky is a partner in Crowell & Moring’s Washington, D.C. office, and serves as a member of the firm’s Health Care Group Steering Committee where he focuses on health care fraud and abuse, and Medicare and Medicaid law and policy. Troy counsels…

Troy Barsky is a partner in Crowell & Moring’s Washington, D.C. office, and serves as a member of the firm’s Health Care Group Steering Committee where he focuses on health care fraud and abuse, and Medicare and Medicaid law and policy. Troy counsels all types of health care entities, including hospitals, group practices, and health plans on the physician self-referral law (Stark Law) and the Anti-Kickback Statute, innovative healthcare delivery models, such as Accountable Care Organizations (ACOs), and Medicare & Medicaid payment and coverage policy. He also defends clients seeking resolution of government health care program overpayment issues or fraud and abuse matters through self-disclosures and negotiated settlements with the U.S. Department of Justice, U.S. Health & Human Services Office of the Inspector General and the Centers for Medicare & Medicaid Services (CMS).

Photo of Lidia Niecko-Najjum Lidia Niecko-Najjum

Lidia Niecko-Najjum is a counsel in Crowell & Moring’s Health Care Group and is part of the firm’s Digital Health Practice. With over 15 years of clinical, policy, and legal experience, Lidia provides strategic advice on health care regulatory and policy matters, with…

Lidia Niecko-Najjum is a counsel in Crowell & Moring’s Health Care Group and is part of the firm’s Digital Health Practice. With over 15 years of clinical, policy, and legal experience, Lidia provides strategic advice on health care regulatory and policy matters, with particular focus on artificial intelligence, machine learning, digital therapeutics, telehealth, interoperability, and privacy and security. Representative clients include health plans, health systems, academic medical centers, digital health companies, and long-term care facilities.

Lidia’s experience includes serving as a senior research and policy analyst at the Association of American Medical Colleges on the Policy, Strategy & Outreach team. Lidia also practiced as a nurse at Georgetown University Hospital in the general medicine with telemetry unit and the GI endoscopy suite, where she assisted with endoscopic procedures and administered conscious sedation.

Photo of Allison Kwon Allison Kwon

Allison Kwon supports Crowell Health Solutions, a strategic consulting firm affiliated with Crowell & Moring, to help clients pursue and deliver innovative alternatives to the traditional approaches of providing and paying for health care, including through digital health, health equity, and value-based health…

Allison Kwon supports Crowell Health Solutions, a strategic consulting firm affiliated with Crowell & Moring, to help clients pursue and deliver innovative alternatives to the traditional approaches of providing and paying for health care, including through digital health, health equity, and value-based health care. She is a health care policy consultant in the Washington, D.C. office.

Photo of Sarah Cheney Sarah Cheney

Sarah Cheney supports Crowell Health Solutions, a strategic consulting firm affiliated with Crowell & Moring, to help clients pursue and deliver innovative alternatives to the traditional approaches of providing and paying for health care, including through digital health, health equity, and value-based health…

Sarah Cheney supports Crowell Health Solutions, a strategic consulting firm affiliated with Crowell & Moring, to help clients pursue and deliver innovative alternatives to the traditional approaches of providing and paying for health care, including through digital health, health equity, and value-based health care. She is a healthcare policy intern in the Washington, D.C. office.

Prior to joining Crowell Health Solutions, Sarah worked at a government affairs and intelligence company where she provided healthcare policy consulting services to clients. As an associate consultant, she led regulatory compliance projects for clients interested in drug affordability and transparency. She also monitored legislative updates to public and private insurance options related to coverage, expansion, fraud, and abuse. Sarah also worked as a Policy Analyst under Wisconsin Governor Tony Evers’ Advisory Council on Equity and Inclusion. She graduated from the University of Wisconsin Madison with a Bachelor’s of Science in Legal Studies and is currently a Master of Public Policy student at The George Washington University.