If you or your practice are based in the United States, then the US version of our Terms of Service and the US version of our End User Terms apply to you.
If you or your practice are not in the United States, then the outside USA version of our Terms of Service and outside USA version of our End User Terms apply to you.
RTM POLICY
Physitrack Platform
Clinician Remote Therapeutic Monitoring (RTM) Policy for the Physitrack Platform
Effective Date: May 2026
For Distribution and Use in the USA only · DOC ID: PHT-RTM-003 (POL) Rev. 01
1. Purpose
This policy provides general guidance on the use of the Remote Therapeutic Monitoring (RTM) feature within the Physitrack Platform. It does not constitute clinical protocols or directives regarding healthcare delivery. All clinical practice and billing decisions remain the sole responsibility of the Customer and its clinicians.
Physitrack makes this policy available to its customers as informational guidance to support the Customer’s own efforts to ensure compliant use of the RTM feature. Physitrack does not instruct, direct, or supervise any aspect of the Customer’s clinical practice. Responsibility for determining applicable clinical practice requirements, and for ensuring that clinicians who use the Physitrack platform comply with those requirements, rests solely with the Customer. The Customer is strongly encouraged to develop its own RTM policy covering the scope of appropriate clinical use and billing standards.
2. Scope
This policy applies to all clinicians and clinical support staff who use the Physitrack RTM feature, including:
- Physical Therapists (PTs)
- Occupational Therapists (OTs)
- Speech-Language Pathologists (SLPs)
- Chiropractors and Osteopaths
- Physical Therapist Assistants (PTAs) and Occupational Therapist Assistants (OTAs) — operating under appropriate supervision
- Care coordinators and admin staff supporting RTM workflows
The Customer must ensure that all relevant staff are aware of, trained on, and compliant with applicable clinical practice requirements. Physitrack accepts no liability for non-compliance arising from the Customer's failure to communicate or enforce these requirements.
3. Customer Responsibilities
Physitrack provides the RTM feature and publishes this guidance to support compliant use. As a software provider, Physitrack does not supervise, employ, or manage clinicians. The Customer is solely responsible for identifying and complying with all applicable clinical, regulatory, and legal requirements. Accordingly, the following responsibilities rest with the Customer:
3.1 Training and Competency
- The Customer is responsible for ensuring that all clinicians using the RTM feature have received adequate training on the Physitrack platform; and
- Ensuring that staff have the clinical competency and platform proficiency required to deliver RTM safely before enabling the feature.
3.2 Regulatory and Payer Obligations
- The Customer is responsible for ensuring that use of Physitrack RTM complies with all applicable federal and state regulations, Medicare conditions of participation, CMS billing requirements, and payer-specific requirements, and
- Maintaining an internal billing compliance program and ensure that RTM billing is reviewed by qualified billing and compliance personnel before submission.
- Consult your compliance team or legal counsel with specific questions.
4. What is Remote Therapeutic Monitoring?
Remote Therapeutic Monitoring (RTM) is a CMS-approved service that allows eligible providers to be reimbursed for remotely monitoring and managing patients using a device that meets the FDA definition of a medical device.
Unlike Remote Patient Monitoring (RPM), RTM focuses on non-physiological data, including patient adherence to prescribed home exercise programs, patient-reported outcomes, and therapy response and symptom progression.
5. Clinician Responsibilities
5.1 Patient Selection
The Customer must establish patient selection criteria appropriate to its scope of practice and patient population, and apply those criteria before enrolling any patient in RTM.
5.2 Patient Consent
The Customer must obtain and document appropriate patient consent in accordance with applicable laws, regulations, and clinical standards before RTM services begin.
5.3 Enrolling a Patient in Physitrack
The following platform steps describe the general workflow for enabling RTM monitoring for a patient within Physitrack:
- Log in to Physitrack and open the patient's profile.
- Assign a Home Exercise Program (HEP) or Pathway appropriate to the patient's condition.
- Enable RTM for the episode of care within the patient record settings.
- Provide the patient with instructions on downloading PhysiApp and logging in.
Customer-side enrollment activities, including patient education, expectation-setting, and clinical documentation, are the Customer’s responsibility.
5.4 Ongoing Monitoring
The treating clinician or designated care coordinator is responsible for clinical management of RTM episodes, including review of RTM data, clinical responses, and documentation, in accordance with Customer protocols. The Customer must define response-time expectations, escalation paths, and clinical review cadence.
5.5 Interactive Communication Requirement
Treatment management billing under RTM requires interactive communication in accordance with current CMS guidance. The Customer is responsible for ensuring compliance with the applicable CMS interactive communication requirements.
5.6 Supervision of PTAs and OTAs
Supervision of PTAs and OTAs performing RTM activities must comply with applicable CMS rules and state practice acts. The Customer must ensure appropriate supervision arrangements are in place.
6. Documentation Requirements
Documentation must support all RTM services billed. The Customer must ensure that documentation standards meet applicable CMS, payer, and regulatory requirements and are sufficient to substantiate any submitted claims.
7. Platform Billing Workflow
The Physitrack Platform provides RTM analytics and milestone alerts to support billing workflows. The following platform steps are supported:
- At the end of each 30-day monitoring period, the RTM dashboard in Physitrack displays the number of days data was transmitted.
- RTM activity reports can be exported from Physitrack and attached to the billing record.
Selection of billing codes, confirmation that interactive communication requirements have been met, validation of clinician management time, and submission of claims to payers are the responsibility of the Customer's billing and compliance personnel. Physitrack RTM Milestone Alerts notify users when patients are approaching billing thresholds.
8. Patient-Facing Communication
The Customer is responsible for all patient-facing communication regarding RTM enrollment, expectations, and ongoing engagement.
9. Data Accuracy Disclaimer
Physitrack provides the Platform to facilitate collection, transmission, and display of patient-generated data. While Physitrack takes reasonable steps to ensure platform reliability and availability, Physitrack accepts no responsibility or liability for:
- The accuracy, completeness, or clinical validity of any data entered by patients or clinicians via the platform.
- Errors or omissions in patient-reported outcomes, exercise logs, or other data recorded through the Platform.
- Clinical decisions made by clinicians on the basis of data collected through the platform.
- Any adverse patient outcomes arising from reliance on inaccurate, incomplete, or misinterpreted RTM data.
The Customer and its clinicians are solely responsible for verifying the accuracy of RTM data, exercising independent clinical judgement when interpreting that data, and ensuring that any clinical decisions are made in accordance with applicable standards of care.
Physitrack does not review, validate, or audit patient-level data entered into the platform. Any data displayed within Physitrack reflects what has been submitted by users of the platform and should not be treated as independently verified clinical information.
Disclaimer
Nothing in this policy constitutes medical, clinical, legal, or billing advice, nor does it constitute instructions regarding clinical practice requirements. Physitrack publishes this policy in its capacity as a software provider for informational purposes only. Clinical and regulatory responsibility for the use of the RTM feature rests with the Customer and the individual clinicians using the platform.
