2026 Changes Coming
Data Collection Best Practices:
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Track data collection dates meticulously
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Document data gaps and patient communication about missing days
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Use automated systems to monitor compliance with 16-day requirement
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Maintain audit trail of all data transmission records
The AMA CPT Editorial Panel approved new codes effective January 2026 that will include a device code covering 2 to 15 days of data transmission, expanding from the 16 days currently required. This will provide more flexibility for short-term monitoring scenarios.
Provider Eligibility: Who Can Bill RTM Codes?
Qualified Healthcare Professionals for RTM Billing:
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Physicians (MDs, DOs) - All RTM codes
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Physical Therapists (PTs) - All RTM codes within scope of practice
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Occupational Therapists (OTs) - All RTM codes within scope of practice
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Speech-Language Pathologists (SLPs) - All RTM codes within scope of practice
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Nurse Practitioners (NPs) - All RTM codes
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Physician Assistants (PAs) - All RTM codes
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Clinical Social Workers - RTM codes within scope of practice
Important Billing Limitations:
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One practitioner rule: Only one practitioner can bill RTM codes per patient per 30-day period
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Supervision requirements: Therapy assistants must work under general supervision (effective January 2024)
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Scope of practice: All services must align with state and professional scope of practice laws
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Personal furnishing: RTM services must be personally furnished by the billing practitioner
Required Documentation for RTM Billing Success
Medical Necessity Documentation Checklist
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Initial evaluation documenting condition requiring RTM
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Treatment plan specifying therapeutic goals and monitoring parameters
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Medical condition documentation (musculoskeletal, respiratory, or CBT-appropriate condition)
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Clinical rationale for remote monitoring vs. traditional care
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Expected outcomes and monitoring frequency justification
Patient Consent Requirements
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Informed consent for RTM services (written documentation required)
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Technology consent for data collection and transmission
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Privacy acknowledgment for HIPAA-compliant data handling
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Communication preferences (how patient wants to be contacted)
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Consent timing - obtained before or at time of service initiation
Device Setup Documentation
(98975)
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Device type and FDA medical device classification
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Patient education provided (specific training topics)
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Setup completion date and verification of device functionality
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Patient demonstration of proper device use
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Troubleshooting guidance provided to patient
Treatment Management Documentation (98980/98981)
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Time logs with start/stop times for each clinical activity
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Data review notes analyzing patient-submitted information
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Interactive communication records (date, duration, content)
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Clinical decision-making based on RTM data
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Care plan modifications resulting from monitoring insights
Current RTM CPT Codes for 2025 - What Each Code Covers
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What it covers: Initial setup and patient education for RTM device(s) and software
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Requirements: First-time device configuration, patient training, consent documentation
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Billing frequency: Once per device per patient (one-time setup)
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Average reimbursement: $19.46 (Medicare non-facility rate)
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Who can bill: Physician or qualified healthcare professional (PT, OT, SLP under scope of practice)
RTM CPT Code 98975: Device Setup and Patient Education
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What it covers: Supply of device for 30 days of respiratory system monitoring data collection
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Requirements: 16 days of data collection within 30-day period minimum
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Data types: Peak flow, spirometry readings, inhaler usage, breathing exercises
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Average reimbursement: $55.63 (Medicare non-facility rate)
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Medical necessity: Must document respiratory condition requiring monitoring
RTM CPT Code 98976: Respiratory System Monitoring (Device Supply)
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What it covers: Supply of device for 30 days of musculoskeletal system monitoring data collection
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Requirements: 16 days of data collection within 30-day period minimum
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Data types: Range of motion, exercise adherence, pain scores, functional assessments
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Average reimbursement: $55.63 (Medicare non-facility rate)
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Medical necessity: Must document musculoskeletal condition requiring therapeutic monitoring
RTM CPT Code 98977: Musculoskeletal System Monitoring (Device Supply)
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What it covers: First 20 minutes of RTM treatment management services per calendar month
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Requirements: Interactive communication with patient/caregiver during the month
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Activities included: Data review, care plan adjustments, patient consultation, clinical management
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Average reimbursement: $49.78 (Medicare non-facility rate)
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Documentation: Must log time distribution and clinical activities
RTM CPT Code 98980: Treatment Management Services (First 20 Minutes)
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What it covers: Each additional 20 minutes beyond the first 20 minutes (98980)
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Requirements: Same as 98980, billed for extended monitoring time
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Maximum billing: No monthly limit established by CMS
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Average reimbursement: $39.14 (Medicare non-facility rate)
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Documentation: Detailed time logs required for each 20-minute increment
RTM CPT Code 98981: Additional Treatment Management (Each Additional 20 Minutes)
RTM vs RPM: Key Billing Differences You Must Know
Factor | RTM (Remote Therapeutic Monitoring) | RPM (Remote Patient Monitoring) |
|---|---|---|
Concurrent Billing | Cannot bill RTM and RPM for same patient/month | Cannot bill RTM and RPM for same patient/month |
16-Day Data Requirement | Only 98976, 98977 (device supply codes) | 99454 (device supply code) |
CPT Codes | 98975, 98976, 98977, 98980, 98981 | 99453, 99454, 99457, 99458, 99091 |
Established Patient Requirement | Not required (but recommended) | Required after PHE end |
Self-Reported Data | Allowed | Not allowed - must be automatically uploaded |
Data Type | Non-physiological (pain scores, exercise adherence, medication compliance) | Physiological (blood pressure, weight, blood glucose) |
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98976 (Respiratory device supply) - 16 days required
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98977 (Musculoskeletal device supply) - 16 days required
Codes Requiring 16 Days of Data:
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98975 (Device setup) - No data requirement
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98980 (First 20 minutes treatment) - No data requirement
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98981 (Additional 20 minutes treatment) - No data requirement