Unlock Remote Therapeutic Monitoring with FairPath
Your expert resource for RTM billing codes, compliance, and therapy monitoring in 2025.
Your RTM Roadmap
What Is Remote Therapeutic Monitoring?
Introduced in 2022, Remote Therapeutic Monitoring (RTM) empowers providers to track non-physiologic data—like therapy adherence, pain levels, or respiratory status—using FDA-approved devices or software, often with patient self-reports.
Unlike RPM's focus on vital signs, RTM targets therapy progress, broadening its reach to physical therapists (PTs), occupational therapists (OTs), and other clinicians beyond traditional E/M providers.
FairPath's guide dives into RTM's billing codes, compliance rules, and practical applications, equipping you with the knowledge to enhance patient care and reimbursement in 2025.
Understanding RTM CPT™ Codes
Decoding RTM
RTM services are billed with CPT™ codes covering setup, device supply, and management. Here's a breakdown based on Medicare's 2025 guidelines:
CPT™ 98975: Initial Setup and Patient Education
Description:
Covers one-time setup and training for RTM devices/software.
Requirements:
Billable once per episode of care (treatment start to goal completion); tied to 16+ days of data in the first 30-day period (per CMS).
Who Can Bill:
Physicians, NPs, PAs, PTs, OTs, SLPs, and other qualified providers within scope.
Documentation:
List device/app and confirm patient instruction.
Payment:
~$19 (2025 Medicare estimate).
Common Question:
"Can I bill 98975 without 16 days?" CMS implies it's tied to subsequent monitoring—best to bill after 16 days are confirmed.
CPT™ 98976: Device Supply (Respiratory System)
Description:
Monthly supply for respiratory monitoring (e.g., inhaler use).
Requirements:
16+ days of data (readings/alerts) in 30 days.
Frequency:
Once per 30 days; only one practitioner bills.
Documentation:
Specify FDA-approved device and 16+ days of use.
Payment:
~$50 (2025 estimate).
Common Question:
"Does it cover multiple devices?" No—just one code per period, regardless of devices.
CPT™ 98977: Device Supply (Musculoskeletal System)
Description:
Monthly supply for musculoskeletal monitoring (e.g., exercise adherence).
Requirements:
Same as 98976—16+ days required.
Frequency:
Once per 30 days; no overlap with other RTM/RPM codes.
Documentation:
Note device and data collection.
Payment:
~$50 (2025 estimate).
Common Question:
"Can I bill for pain logs?" Yes, if via an FDA-approved tool.
CPT™ 98978: Device Supply (Cognitive Behavioral Therapy)
Description:
Monthly supply for CBT monitoring (new in 2024).
Requirements:
FDA-approved digital tool; 16+ days of data.
Frequency:
Once per 30 days; contractor-priced by Medicare.
Documentation:
Specify CBT device/app and usage.
Payment:
Varies by MAC (~$40-$60 estimated).
Common Question:
"Is it widely covered?" Check with payers—adoption varies.
CPT™ 98980: Treatment Management (First 20 Minutes)
Description:
20+ minutes of management, including data review and interactive communication.
Requirements:
Real-time contact (phone/video); 16-day rule doesn't apply.
Frequency:
Once per calendar month.
Who Can Bill:
Same as above; staff assist under general supervision.
Documentation:
Log time (e.g., "15-min review, 5-min call on 3/15").
Payment:
~$50 (2025 estimate).
Common Question:
"What if I miss the call?" No interactive contact means no billing.
CPT™ 98981: Additional Management Time
Description:
Add-on for each extra 20 minutes beyond the first 20.
Requirements:
Full 20-minute increments; further interaction recommended.
Frequency:
Multiple units if justified.
Documentation:
Detail additional time and actions.
Payment:
~$40 per unit (2025 estimate).
Common Question:
"How many units can I bill?" No cap, but justify with complexity.
General Notes:
RTM can't be billed with RPM for the same patient in the same period. Stackable with CCM if time is distinct.
Timing Your Success
How RTM Billing Works
RTM operates on distinct cycles:
Device Codes (98976–98978):
Bill once per 30-day period after 16+ days of data, using the period's end date (e.g., Feb 8 for Jan 10–Feb 8).
Management Codes (98980–98981):
Bill once per calendar month after 20+ minutes, typically on the last day (e.g., March 31).
Setup (98975):
Bill once per episode when monitoring begins.
Process:
Track device use daily; log management time monthly.
Common Question: "What if monitoring starts mid-month?" Bill device codes after 30 days; management codes align to the month.
Tip: Use RTM platforms for usage logs.
Tech That Transforms
Tools for RTM Excellence
RTM thrives on technology:
FDA-Defined Devices
Apps or hardware (e.g., Propeller Health, Kaia Health) track therapy data.
Software Eligibility
FDA-cleared apps qualify (e.g., CBT tools for 98978); document status.
RTM Platforms
Tools like Zimmer Biomet's mymobility log days and minutes, syncing with EHRs.
Communication
Synchronous calls or video count toward 98980/98981 time.
Common Question: "Can I use a non-FDA app?" Risky—stick to approved devices for compliance.
Best Practice: Leverage dashboards to ensure 16+ days.
Protecting Your Practice
Navigating RTM Compliance
RTM demands vigilance:
16-Day Rule
Verify 16+ days of data for device codes; OIG flags non-compliance (e.g., RPM audits).
Time Accuracy
Log 20+ minutes for 98980/98981; no double-counting with CCM/RPM.
Consent
Document patient agreement—best practice, though not mandated.
Fraud Risks
OIG notes overbilling (e.g., 28% of RPM enrollees lacked setup claims).
Vendor Deals
Structure third-party fees at fair market value to avoid kickback issues.
Common Question: "What if I miss 16 days?" Skip billing—audits can recoup funds.
Tip: Audit logs monthly (e.g., "20 days of data, 11/15 call").
Who Pays for RTM?
Medicare, MA, Medicaid, and Private Coverage
Medicare Part B
Covers all codes; 20% coinsurance applies (~$10–$12 per code).
Medicare Advantage (MA)
Matches Medicare; some offer $0 copays.
Medicaid
Varies—states like Virginia cover RTM; others lag (rates ~$20–$30).
Private Insurers
Aetna, BCBS (e.g., MA, MI) pay; Cigna lags; rates ~120% of Medicare.
Common Question: "Will my payer cover 98978?" Verify—new codes face adoption delays.
Trend: Coverage grows as RTM proves value.
What's New in RTM
RTM Updates for 2025
2024 Changes
CPT 98978 added for CBT; general supervision clarified.
2025 Outlook
AMA proposes dropping 16-day rule by 2026; new 10–19-minute codes pending.
Payment
98978 carrier-priced; slight PFS rate tweaks (~$50 for 98980).
Common Question: "Will 16-day relax sooner?" Watch 2025 PFS—possible early adoption.
Trend: Digital therapeutics expand RTM's reach.
Ready to Optimize Your RTM Program?
FairPath helps you navigate RTM billing, compliance, and patient care with expert guidance.
Contact Our RTM Experts