Research report

A research report is the sourced material a domain dossier is synthesized from — generated on a plan and a cadence, one topic per file. A report carries no confidence tags. Its bracketed markers say who might have an incentive to shade a line; none of them says anyone checked it. To reach a score, a line has to be drafted onto a candidate as unverified and pass the Verifier or the Corroborator, like everything else.

Section reimbursement · Version 2026-09-19 · Cadence quarterly · Evidence class 1 registry · Sources 2 · Supersedes none

Domain: stress-urinary-incontinence · Scope: CMS (Centers for Medicare & Medicaid Services)'s own published rulemaking and manual-transmittal commentary on the Remote Therapeutic Monitoring code family, scoped to the question of which body systems the device-supply codes reach. AMA CPT (Current Procedural Terminology) descriptor text is licensed and is NOT reproduced here — this report states the scope CMS's own commentary describes and quotes CMS, never the descriptor. Excludes payment rates, the RTM (remote therapeutic monitoring) treatment-management codes' time thresholds, commercial payer RTM policy, and the CY2026 PFS (physician fee schedule) RTM provisions, which were identified as live but not retrieved this pass.

Sourcing: Rests on one CMS manual transmittal retrieved and read in full (Transmittal 11118 / CR 12446), plus one secondary characterization of CY2022 PFS rulemaking used only for the narrow point that CMS considered and declined a system-agnostic device code — that point is marked single-source and secondary, and the underlying final rule was not retrieved.

What body systems the RTM device-supply codes reach, and whether pelvic floor is one of them — stress urinary incontinence

1. Summary

The Remote Therapeutic Monitoring code family was added to Medicare's therapy code list by CMS Transmittal 11118 (Change Request 12446), dated 2021-11-10, implementing policies discussed in CY2022 Physician Fee Schedule rulemaking [1]. The family is organized around body-system status, and the two systems it names are the respiratory system and the musculoskeletal system, alongside therapy adherence and therapy response [1]. There are two device-supply codes, one scoped to monitoring the respiratory system and one to monitoring the musculoskeletal system [1]. Pelvic floor, genitourinary, urologic, bladder, continence and incontinence appear nowhere in the transmittal — a full-text search of all four pages returns no occurrence of any of those terms [1]. The correct answer to "is pelvic floor named, excluded, or unaddressed" is therefore unaddressed. Whether pelvic floor muscle status falls inside "musculoskeletal system status" is not answered by CMS in this document, in either direction. Separately, CMS is reported to have considered and declined a generic, system-agnostic device-supply code that would have removed the body-system restriction [2] [single-source]; that point rests on a secondary characterization and the underlying final rule was not retrieved.

2. What Changed

_Baseline (v1). No prior version; this establishes the starting point for future diffs._

3. Details

What the transmittal establishes

CMS Transmittal 11118, Pub. 100-04, Change Request 12446, dated 2021-11-10, rescinds and replaces Transmittal 11036 of 2021-10-13 [1]. Its stated purpose is to update the list of codes that sometimes or always describe therapy services, and it states that "The policies implemented in this notification were discussed in CY (calendar year) 2022 Medicare Physician Fee Schedule rulemaking" [1].

The transmittal introduces five codes into that list: an initial set-up and patient education code, two device-supply codes, and two treatment-management codes [1]. The descriptors are printed in the transmittal and are AMA-licensed; they are deliberately not reproduced here. What is recorded instead is the scope those descriptors describe, which is a fact about the code family rather than the licensed text:

The family as a whole is framed around four things: respiratory system status, musculoskeletal system status, therapy adherence, and therapy response [1].
Of the two device-supply codes, one transmits data to monitor the respiratory system and the other to monitor the musculoskeletal system [1]. These are the only two body systems the device-supply half of the family reaches.

What it does not establish, which is the question that was asked

A full-text search of the transmittal for pelvic, genitourinary, urologic, continen, incontinen and bladder returns no occurrence of any term across all four pages [1].

So CMS, in the document that put these codes on the therapy list, does not address pelvic floor muscle status at all. It is not named as included and it is not named as excluded. Three readings follow, and only the first is established:

Established: the device-supply code that would have to carry a pelvic floor device is the musculoskeletal-system one, because it is the only one of the two that could plausibly apply — the other is respiratory [1].
Not established, and plausible: that pelvic floor muscle is musculoskeletal. The pelvic floor is skeletal muscle, and on an anatomical reading "musculoskeletal system status" reaches it. CMS does not say this [1].
Not established, and equally available on this evidence: that CMS or a contractor would read the musculoskeletal-status code as directed at orthopaedic and physical-medicine indications and decline it for a continence device. Nothing in the transmittal forecloses this reading either [1].

An absence of language is not a permission. The question REQ-0023 was raised to settle — whether the recurring-revenue leg of this candidate's money model is available or merely assumed — is not settled by this document. It is narrowed to a determination nobody has made in writing.

The declined generic code, and why it matters here

A secondary source characterizing the CY2022 final rule reports that CMS received comments asking for a general device code that would be system-agnostic and not restrict RTM to musculoskeletal and respiratory monitoring, and that CMS did not implement one [2] [single-source]. If accurate, that matters more than its length suggests: it means the body-system restriction is a deliberate retained boundary rather than an oversight nobody has revisited, which makes a permissive reading of "musculoskeletal" less safe, not more. The CY2022 final rule itself was not retrieved this pass and this point should be treated as unconfirmed until it is.

An adjacent CMS position worth reading alongside this

Outside this report's sources but on the record elsewhere in this candidate's evidence base: Medicare NCD (national coverage determination) 30.1.1 excludes home use of biofeedback therapy from coverage. That is CMS declining to pay for monitoring the same muscle group in the same setting under a different benefit. It does not decide the RTM question — different code family, different benefit, different rulemaking — but it is a reason to retrieve the RTM answer rather than assume a favourable one.

4. Sources

[1] "Remote therapeutic monitoring" — CMS Manual System, Pub. 100-04 Medicare Claims Processing, Transmittal 11118, Change Request 12446 (published 2021-11-10; accessed 2026-09-19). CMS Pub. 100-04 Transmittal R11118CP (Transmittal 11118), CR 12446 — https://www.cms.gov/files/document/r11118cp.pdf [federal-registry] [2] "2022 Medicare Remote Therapeutic Monitoring FAQs: CMS Final Rule" — Upper Midwest Telehealth Resource Center (published 2021-11-30; accessed 2026-09-19). Characterizes CY2022 Medicare Physician Fee Schedule final rule commentary on a proposed system-agnostic RTM device code; the final rule itself was not retrieved, and this source carries no registry identifier of its own [no-identifier] — https://www.umtrc.org/news/2021/11/30/general/2022-medicare-remote-therapeutic-monitoring-faqs-cms-final-rule/ [other]

5. Sourcing & Gaps

Well established: The RTM code family's body-system framing, the existence of exactly two device-supply codes scoped to respiratory and musculoskeletal monitoring respectively, and the complete absence of pelvic floor, genitourinary, urologic, bladder and continence terms from the transmittal. All rest on CMS's own document, read in full [1].

Thin: The declined system-agnostic device code rests on one secondary, non-federal source and is marked [single-source] in §3 [2]. It should not be cited downstream without retrieving the CY2022 final rule.

Rescoped from class 3: None.

Out of scope: AMA CPT descriptor text, which is licensed and is not reproduced anywhere above — this report states code scope and quotes CMS's own prose only. Payment rates, the treatment- management codes' time and interactive-communication thresholds, and commercial payer RTM policy.

Not searched vs. not found:

Pelvic floor and its cognates were searched for and not found in [1]. That is a confirmed absence within that document, not a confirmed absence from CMS's position generally.
The CY2022 PFS final rule (CMS-1751-F) itself was not retrieved. REQ-0023 asked for it by name. This pass reached the implementing transmittal instead, which is a primary CMS document but a different one, and the rule's preamble commentary is where any discussion of what "musculoskeletal" reaches would live.
The CY2023 and CY2024 RTM provisions were not searched.
The CY2026 PFS RTM provisions were not retrieved and are a live gap. A vendor source encountered in search indicates CMS updated RTM codes in the CY2026 Physician Fee Schedule. This report is dated 2026-09-19 and a CY2026 change could have altered the body-system boundary described above. Treat the scope stated here as the 2021 baseline, not as confirmed current.
The CMS RTM billing FAQ, also named by REQ-0023, was not retrieved.

[inference] One, marked in §3: that the musculoskeletal-status device-supply code is the only one of the two that could carry a pelvic floor device. That is elimination over the two codes CMS names, not a statement CMS makes.

6. Claim Candidates

Proposition	Evidence class	Resolvable identifier	Dossier section
CMS Transmittal 11118 / CR 12446 added the RTM code family to the Medicare therapy code list, implementing policies discussed in CY2022 Physician Fee Schedule rulemaking	1 registry	CMS Pub. 100-04 Transmittal 11118; CR 12446	reimbursement
The RTM device-supply codes reach two body systems only — respiratory system and musculoskeletal system — with no third device-supply code for any other system	1 registry	CMS Pub. 100-04 Transmittal 11118	reimbursement
Pelvic floor, genitourinary, urologic, bladder and continence terms appear nowhere in CMS Transmittal 11118, so CMS neither includes nor excludes pelvic floor muscle status from musculoskeletal system status in that document	1 registry	CMS Pub. 100-04 Transmittal 11118	reimbursement

Words on this page6 abbreviation(s) and code(s), with what each stands for — copied from _shared/plain-language.md

CMS: Centers for Medicare & Medicaid Services — the US agency that runs Medicare, and so decides what Medicare pays for
CPT: Current Procedural Terminology — the US billing codes for what a clinician does; owned by the American Medical Association
CY: calendar year — the year a Medicare rule or fee schedule applies to
NCD: national coverage determination — a Medicare rule, valid everywhere in the US, saying whether and when something is covered
PFS: physician fee schedule — the Medicare price list for what clinicians do
RTM: remote therapeutic monitoring — billing codes that pay a clinician for following a patient's use of a device from a distance

Generated from knowledge-base/research/stress-urinary-incontinence/reimbursement/current/rtm-device-supply-code-scope_2026-09-19.md by engine/scripts/build_review.py on 2026-10-04. This page is a view — edit the source file and rebuild, never edit here.