The RTM Code Set at a Glance
Remote Therapeutic Monitoring was formalized by CMS in the 2022 Physician Fee Schedule, giving practices a structured billing framework for monitoring patient-reported data — therapy adherence, pain levels, medication compliance, and behavioral health — outside of in-person visits. The RTM code set runs from CPT 98975 through CPT 98981, and each code serves a distinct clinical and billing purpose. Unlike Remote Patient Monitoring (RPM), which requires physiologic data collection via FDA-cleared devices, RTM captures non-physiologic data, opening the door for physical therapists, occupational therapists, chiropractors, and behavioral health providers who could not previously bill RPM.
The six codes break into three functional tiers: initial setup (98975), device supply by system type (98976, 98977, 98978), and treatment management (98980, 98981). Understanding which code belongs to which tier — and which combination is appropriate for a given patient — is the foundation of compliant RTM billing. A practice billing all six codes for every RTM patient will face denials; a practice billing only the management codes without the device supply code will leave $50–$60 per patient per month on the table.
CMS publishes national average reimbursement in the Physician Fee Schedule (PFS); actual payments vary by geographic area using the Geographic Practice Cost Index (GPCI). Practices in high-cost markets like New York, Los Angeles, or Boston typically receive 10–15% above the national average. Medicare Advantage plans often reimburse at Medicare rates but may apply additional prior authorization requirements. Commercial payers are a patchwork — some follow Medicare logic, others require separate contracting. Before launching an RTM program, verify coverage and rates with your top five payers by volume.
The 2025 PFS maintains stable RTM reimbursement with minor geographic adjustments. Total monthly RTM revenue per enrolled patient — combining one device supply code and the first treatment management code — runs approximately $100–$130 under Medicare, before adjustments. When you multiply that across even 50 enrolled patients, RTM adds $5,000–$6,500/month in recurring revenue without adding appointment slots.
CPT 98975: Initial Setup and Patient Education (One-Time)
CPT 98975 is the one-time setup code billed when a patient is enrolled in an RTM program and educated on how to use the monitoring device or software platform. CMS reimburses this code at approximately $20–25 nationally. It is billed once per patient per RTM episode of care — not monthly — and it should be billed in the same month the patient is enrolled and the device or app is supplied and activated.
Documentation for 98975 must capture: (1) the date of enrollment, (2) the type of device or application provided, (3) that patient education on device use was completed, and (4) the patient's understanding and consent to participate. Many practices document this within the EHR visit note or in a standalone RTM enrollment note. If your practice uses a paper-based consent, ensure the signed consent is scanned into the chart and linked to the billing encounter.
A critical rule: 98975 cannot be billed in the same 30-day period as CPT 99453, the analogous setup code for RPM. If a patient is enrolled in both RTM and RPM simultaneously — which is clinically appropriate in some cases, for example a spine surgery patient wearing an RPM blood pressure cuff while also using an RTM pain-reporting app — you must bill the setup codes in separate calendar months or document clearly which applies to which program.
Commercial payer rules vary. Some payers reimburse 98975 at rates comparable to Medicare; others bundle setup into the first month's device supply code and deny 98975 as a standalone charge. Check your top commercial payer contracts explicitly for 98975 language before billing. When in doubt, submit with full documentation and appeal denials — overturn rates for 98975 denials with complete documentation run above 60% at most major payers.
CPT 98976: Respiratory System RTM Device Supply
CPT 98976 covers the monthly supply of a medical device used to collect and transmit RTM data for respiratory system conditions — primarily COPD, asthma, and post-COVID respiratory monitoring. This code is billed once per 30-day period and requires that the device was used and data was transmitted to the practice at least 16 days out of the 30-day monitoring period. CMS national reimbursement for 98976 is approximately $45–55/month.
The most common clinical applications include digital peak flow meters, smart inhaler sensors that track medication adherence and technique, and symptom-reporting apps that prompt patients to log daily respiratory status. A patient with moderate persistent asthma who uses a connected smart inhaler (such as Propeller or Hailie) can generate compliant 98976 data automatically. Documentation must confirm the 16-day threshold was met — most RTM platforms generate a compliance report that should be saved to the patient's chart at the time of billing.
A persistent compliance risk with 98976 involves the data transmission requirement. The patient must not merely use the device — the data must be transmitted to the practice's clinical team. If a patient self-reports through an app but the data is not ingested by the practice's system (for example, due to Bluetooth pairing failures or app permission issues), the monitoring period does not count toward the 16-day minimum. Practices should implement a mid-month check-in workflow to identify patients at risk of not meeting the threshold before the billing period closes.
Payer note: Several major commercial payers, including UnitedHealthcare and Cigna, have published clinical policy bulletins (CPBs) confirming coverage for 98976 in COPD and asthma. Anthem's coverage policies vary by state; verify your specific regional plan. Medicaid programs in most states do not yet cover 98976, though several state programs are in active rulemaking.
CPT 98977: Musculoskeletal System RTM Device Supply
CPT 98977 is the highest-volume RTM device supply code in most practices, covering monthly device supply for musculoskeletal (MSK) conditions — back pain, joint pain, post-surgical recovery, and sports injuries. CMS reimburses 98977 at approximately $50–60/month, making it the anchor of RTM revenue for orthopedic surgery, physical therapy, chiropractic, sports medicine, and pain management practices.
The 16-day data transmission rule applies equally to 98977. Patient-reported outcomes (PROs) submitted through an RTM app — including pain scales, range of motion assessments, activity levels, and functional status reports — qualify as RTM data when transmitted through a compliant platform. Wearable devices that track movement, gait, or activity also satisfy the device supply requirement for MSK RTM. Common platforms billing under 98977 include Reflexion Health, MedBridge, RecoveryOne, and proprietary EHR-integrated RTM modules.
For practices with high post-surgical volume, 98977 is particularly powerful because MSK patients have a natural monitoring window — typically 12 weeks of post-op recovery — during which monthly billing is appropriate and clinically justified. A patient recovering from a total knee arthroplasty who uses an RTM app to log daily pain scores and range of motion exercises can generate 3 months of 98977 billing ($150–$180) while the clinical team monitors recovery remotely and intervenes if metrics deteriorate.
Documentation for 98977 must include the diagnosis code (ICD-10) confirming an MSK condition, the type of monitoring device or application used, confirmation that data was transmitted for at least 16 of 30 days, and a clinical note documenting that the transmitted data was reviewed. Many practices create a monthly RTM review note template to standardize this documentation.
CPT 98978: Behavioral Health RTM Device Supply
CPT 98978 is the behavioral health analog of 98976 and 98977, covering monthly device supply for behavioral health conditions — depression, anxiety, PTSD, substance use disorders, and adherence monitoring in psychiatric medication management. This code opened RTM to psychiatrists, psychologists, licensed clinical social workers (LCSWs), and addiction medicine specialists who could not access RPM codes. CMS reimbursement is approximately $40–50/month.
The clinical mechanism for 98978 differs somewhat from other RTM device codes. Rather than a wearable sensor, the "device" is typically a digital health application or structured digital assessment tool — such as a PHQ-9 administered through an app, a mood-tracking platform, or a medication adherence app linked to smart pill dispensers. The 16-day data transmission rule still applies, and the transmitted data must represent patient-generated health data, not just clinician-entered notes.
Compliance concerns unique to 98978 center on patient engagement. Behavioral health patients may disengage from monitoring apps during depressive episodes or psychiatric crises — precisely the periods when monitoring is most valuable. Practices billing 98978 need a staff workflow to identify patients whose data submission drops below threshold early in the billing period, enabling a clinical outreach call that both supports the patient and potentially recovers the monitoring period. Documentation must reflect this outreach if it occurs.
Payer coverage for 98978 is the most variable in the RTM set. Medicare covers 98978 when billed by eligible providers with appropriate ICD-10 codes (F32.x, F33.x, F41.x, F43.x, F10-F19 for SUD). Commercial coverage lags; as of 2025, major payers including Aetna and BCBS are actively reviewing behavioral health RTM policies. Practices should submit with full documentation and expect to appeal approximately 30–40% of initial commercial denials.
CPT 98980: RTM Treatment Management, First 20 Minutes
CPT 98980 is the first monthly treatment management code in the RTM set, covering the initial 20 minutes of clinical staff time spent reviewing RTM data, assessing patient status, and communicating with the patient or caregiver in a calendar month. CMS national reimbursement is approximately $50–70/month, making this the highest-value RTM code on a per-unit basis and the code most directly tied to physician or qualified health care professional (QHP) involvement.
The critical billing requirement for 98980 is that the time must be spent by a physician, nurse practitioner, physician assistant, clinical psychologist, clinical social worker, or physical/occupational therapist (depending on scope of practice) — not by medical assistants or unqualified support staff. The 20-minute threshold is a true time requirement; activities that count toward the 20 minutes include reviewing transmitted data, communicating with the patient via phone or patient portal, documenting clinical decisions based on RTM data, and care coordination related to RTM findings.
Documentation for 98980 must include: (1) the date(s) of RTM review and communication, (2) the name and credentials of the qualified provider performing the review, (3) the total time spent, (4) a clinical summary of findings and any actions taken, and (5) the calendar month covered. Many EHR platforms now include RTM time-tracking modules; if yours does not, a simple time-stamped note in the chart satisfies the requirement.
A common billing error: 98980 cannot be billed without a corresponding device supply code (98976, 98977, or 98978) for the same patient in the same billing period. If the device supply code fails to meet the 16-day threshold, 98980 should not be billed — or if billed, will be denied on audit. Ensure your billing workflow cross-checks device compliance before generating the management code claim.
CPT 98981: RTM Treatment Management, Each Additional 20 Minutes
CPT 98981 covers each additional 20-minute increment of RTM treatment management beyond the first 20 minutes captured by 98980. It is billed in the same calendar month as 98980 when clinical staff spend 40 or more total minutes on RTM management for a single patient. CMS national reimbursement for 98981 is approximately $40–50 per additional unit, making each additional 20-minute block meaningful for complex patients who require more intensive remote oversight.
98981 is appropriate for high-complexity patients — for example, a post-surgical spine patient with delayed recovery and elevated pain scores whose RTM data triggers multiple provider callbacks, a care plan modification, and a scheduler contact to advance the follow-up appointment. In these cases, documented total management time may reach 40–60 minutes, justifying one or two units of 98981 in addition to 98980.
The same qualified provider time requirement applies to 98981 as to 98980. Time spent by medical assistants or administrative staff does not count toward the threshold. However, collaborative time among team members — for example, a PA reviewing the data and communicating with the patient, and then consulting with the attending physician to modify the care plan — can be aggregated in the documentation when both providers contribute substantive clinical effort to the same patient in the same month.
Practice management note: most practices find that fewer than 20% of RTM patients require billing of 98981 in any given month. If your billing data shows 98981 being billed for 50% or more of RTM patients, that is a red flag for auditors suggesting potential upcoding. Conversely, if no patients are generating 98981, consider whether your clinical team is documenting all time spent — underbilling 98981 is a common and easily correctable revenue leak.
Payer Coverage, Documentation, and Audit Risk
Building a compliant and sustainable RTM billing program requires understanding the full audit risk landscape alongside the revenue opportunity. CMS and commercial payers have identified RTM as an area of active scrutiny in 2025, given rapid adoption following the 2022 code launch. The Office of Inspector General (OIG) has flagged telehealth and remote monitoring codes for increased review, and MAC (Medicare Administrative Contractor) post-payment audits for RTM claims are occurring in multiple jurisdictions.
The most common audit findings in RTM billing involve: (1) failure to document the 16-day threshold for device supply codes, (2) management time billed by unqualified staff, (3) 98975 billed more than once per episode, and (4) RTM codes billed for patients who never actively used the monitoring device. A prospective audit of 10–15% of RTM claims monthly — reviewing documentation before claims are submitted — dramatically reduces post-payment recovery risk.
For payer-specific coverage, practitioners should maintain a coverage matrix by payer updated at least quarterly. As of 2025: Medicare covers 98975-98981 under the Physician Fee Schedule. UnitedHealthcare covers 98975, 98977, and 98980 with prior authorization in some plans. Cigna has issued coverage for MSK RTM. Aetna covers RTM in select commercial plans with behavioral health carve-out rules. Most Medicaid programs remain non-covered for RTM. Always verify with current payer policies — coverage is evolving faster than any static reference can track.
Finally, the RTM consent document is both a patient rights requirement and a billing compliance tool. Patients must consent to RTM participation, understand that their data is being transmitted, and agree to the program terms. Signed, dated consent should be retained in the patient's record for at least 7 years per Medicare record retention standards. Treat the consent audit trail as seriously as the clinical documentation.
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