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CPT 98975 is the Current Procedural Terminology code established by the American Medical Association (AMA) and reimbursed by the Centers for Medicare & Medicaid Services (CMS) for the initial setup and patient education on the use of equipment for Remote Therapeutic Monitoring (RTM). Introduced in the Calendar Year (CY) 2022 Medicare Physician Fee Schedule (MPFS) Final Rule as the entry code for the RTM family (CPT 98975–98981), the official code descriptor reads: “Remote therapeutic monitoring (e.g., therapy adherence, therapy response, digital therapeutic intervention); initial set-up and patient education on use of equipment.” While Remote Physiologic Monitoring (RPM) captures objective physiologic parameters such as blood pressure or blood glucose, CPT 98975 initiates monitoring of non-physiologic therapeutic data—including musculoskeletal range-of-motion adherence, respiratory inhaler actuation and technique, pain intensity scales, and digital therapeutic software engagement.
What Is CPT 98975 and How Is It Used in Clinical Research and Healthcare?
In outpatient clinical practice and decentralized clinical trials evaluating physical rehabilitation, respiratory therapeutics, or prescription digital therapeutics (PDTs), CPT 98975 reimburses clinical staff for the one-time onboarding work required to deploy a connected therapeutic medical device or Software as a Medical Device (SaMD). Onboarding encompasses configuring the patient’s hardware sensor or mobile medical application, pairing peripheral motion sensors or smart inhaler attachments, verifying cellular or Wi-Fi data transmission to the clinical portal, and educating the patient or caregiver on daily exercise execution, symptom logging, and transmission schedules.
Unlike the Remote Physiologic Monitoring onboarding code (CPT 99453), which is classified within the Evaluation and Management (E/M) section of the CPT manual and restricted to physicians and Non-Physician Practitioners (NPPs such as nurse practitioners and physician assistants), CPT 98975 is classified in the General Medicine section. Consequently, CMS permits Qualified Health Care Professionals (QHPs) who cannot independently bill E/M codes—specifically Physical Therapists (PTs), Occupational Therapists (OTs), and Speech-Language Pathologists (SLPs)—to order, perform, and bill CPT 98975 directly under an established outpatient therapy plan of care.
| RTM Code | Official Scope & System Target | Billing Frequency & Minimum Threshold | Relationship to CPT 98975 |
|---|---|---|---|
| CPT 98975 | Initial setup and patient education on use of RTM equipment (any eligible therapeutic system) | Once per episode of care; requires at least 16 days of monitored data transmission | Foundational onboarding code for the RTM episode |
| CPT 98976 | Device(s) supply with scheduled recording and/or programmed alert(s) transmission to monitor the respiratory system | Each 30 days; requires at least 16 days of data collection in the 30-day period | Respiratory device supply companion to 98975 |
| CPT 98977 | Device(s) supply with scheduled recording and/or programmed alert(s) transmission to monitor the musculoskeletal system | Each 30 days; requires at least 16 days of data collection in the 30-day period | Musculoskeletal device supply companion to 98975 (e.g., Limber Health digital home exercise platforms) |
| CPT 98978 | Device(s) supply with scheduled recording and/or programmed alert(s) transmission to monitor cognitive behavioral therapy (CBT) | Each 30 days; contractor-priced under Medicare | CBT digital therapeutic supply companion to 98975 |
| CPT 98980 | RTM treatment management services, physician or other QHP time in a calendar month requiring at least one interactive communication | First 20 minutes per calendar month | Monthly clinical review and care management of RTM data |
| CPT 98981 | RTM treatment management services, each additional 20 minutes in a calendar month (add-on code to 98980) | Each additional 20 minutes per calendar month | Extended monthly clinical management add-on |
What Standards or Regulatory Requirements Govern CPT 98975?
To submit a compliant claim for CPT 98975 under Medicare and commercial payers following AMA CPT guidelines, healthcare organizations and research billing offices must satisfy five core regulatory conditions:
- FDA Medical Device Qualification: The hardware sensor or software application used to capture therapeutic data must meet the statutory definition of a medical device under Section 201(h) of the Federal Food, Drug, and Cosmetic Act (FD&C Act) (Cleared via 510(k), De Novo granted, Premarket Approved, or operating under applicable FDA enforcement discretion/registration as a medical device). General consumer fitness trackers or unvalidated wellness apps do not qualify.
- The 16-Day Data Transmission Prerequisite: Per AMA CPT parenthetical rules,
CPT 98975“may be reported once per episode of care” and cannot be billed unless monitoring occurs for at least 16 days. Even though the clinical education session happens on Day 1, the billing system must hold the98975claim until the patient has actively recorded and transmitted therapeutic data on at least 16 separate calendar days. - Once-Per-Episode Limitation: An episode of care for RTM begins when the remote therapeutic monitoring service is initiated and ends when the targeted treatment goal is attained or the therapy plan of care is discharged. Providers cannot re-bill
CPT 98975every 30 days or when swapping a replacement sensor within the same therapeutic episode. - Self-Reported Data Permissibility via Medical Device: Unlike RPM device supply (CPT 99454), where physiologic measurements must be automatically and non-self-reportedly synced by hardware sensors, CMS explicitly permits RTM data under
CPT 98975–98978to include patient self-reported inputs (such as visual analog pain scores, perceived exertion, or exercise completion logs), provided those inputs are entered into and transmitted through an FDA-defined medical device or SaMD platform. - Non-Duplication with RPM: CMS prohibits billing both RTM (
98975–98981) and RPM (99453–99458, including CPT 99457) for the same patient during the same time period, even if separate devices are monitoring physiologic and musculoskeletal parameters.
How Does CPT 98975 Integrate with EHR and Health Informatics Workflows?
Integrating CPT 98975 into an electronic health record (EHR) and revenue cycle management (RCM) pipeline requires automated transmission-day tracking and therapy modifier logic:
- Automated 16-Day Claim Hold Queues: When a clinician or clinical staff member documents the initial RTM onboarding encounter on Day 1, the EHR or patient remote monitoring platform places the
CPT 98975charge in a pending holding queue. An ingestion counter tracks unique calendar days with valid HL7 FHIRObservationorQuestionnaireResponsepayloads; only whentransmission_days >= 16does the billing engine releaseCPT 98975alongside the initial 30-day device code (98976or98977). - Therapy Plan-of-Care Modifiers: When billed by physical therapists, occupational therapists, or speech-language pathologists under a Medicare outpatient therapy plan of care, the claim line for
CPT 98975must carry the corresponding therapy discipline modifier:-GP(Physical Therapy),-GO(Occupational Therapy), or-GN(Speech-Language Pathology). Furthermore, when provided in whole or in part by a Physical Therapist Assistant (PTA) or Occupational Therapy Assistant (OTA), the claim must append modifier-CQ(PTA) or-CO(OTA) in accordance with CMS supervision and payment differential rules. - Audit-Ready Onboarding Documentation: The EHR encounter note for
CPT 98975must record the prescribing clinician’s order, the specific FDA-defined device/software name and identifier, confirmation that the patient received education on operating the device, the date of initial activation, and the cumulative 16-day transmission log prior to claim submission.
Frequently Asked Questions
What is CPT 98975 and how is it used in clinical research and healthcare?
CPT 98975 is the AMA procedural code for the initial setup and patient education on the use of equipment for Remote Therapeutic Monitoring (RTM), used once per episode of care to onboard patients onto FDA-defined devices or software monitoring musculoskeletal, respiratory, or cognitive behavioral therapy adherence and response.
What standards or regulatory requirements govern CPT 98975?
CPT 98975 requires the use of a device that meets the FDA definition of a medical device under Section 201(h) of the FD&C Act, can only be billed once per episode of care after at least 16 calendar days of therapeutic data have been collected and transmitted, and cannot be billed concurrently with Remote Physiologic Monitoring (RPM) codes for the same patient in the same month.
How does CPT 98975 integrate with EHR and health informatics workflows?
EHR and RTM billing platforms hold the Day-1 onboarding charge for CPT 98975 in a suspense queue until automated telemetry logs verify 16 distinct days of data transmission, and automatically append mandatory Medicare therapy modifiers (-GP, -GO, or -GN, plus -CQ/-CO for therapy assistants) when billed under a rehabilitation plan of care.
