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CPT 98977 is the Current Procedural Terminology code for Remote Therapeutic Monitoring (RTM) device supply used to monitor the musculoskeletal (MSK) system over a 30-day period. Together with initial setup code CPT 98975, respiratory device supply code CPT 98976, cognitive behavioral therapy (CBT) device supply code CPT 98978, and monthly treatment management codes CPT 98980 and CPT 98981, it forms the complete Medicare billing framework for remote therapeutic monitoring.
In orthopedic rehabilitation, telerehabilitation, pulmonology, and pain management clinics, understanding the specific technical requirements of CPT 98976–98981—including the 16-day data transmission threshold, Physical Therapist (PT) and Occupational Therapist (OT) direct billing rules, and mutual exclusivity with Remote Physiologic Monitoring (CPT 99457 and CPT 99458)—is essential for compliant claim submission.
What Is the Difference Between CPT 98976 (Respiratory RTM Device Supply), CPT 98977 (Musculoskeletal RTM Device Supply), and CPT 98978 (CBT Device Supply)?
Unlike Remote Physiologic Monitoring (RPM), which uses a single universal 30-day device-supply code (`CPT 99454`) regardless of organ system, the AMA CPT Editorial Panel created organ-system-specific 30-day device-supply codes for RTM (`cpt 98976 98977 98978`). Evaluating what is the difference between CPT 98976 (respiratory RTM device supply), CPT 98977 (musculoskeletal RTM device supply), and CPT 98978 (CBT device supply) requires matching the FDA-cleared or FDA-registered medical device to the physiological/therapeutic target:
| CPT Code | Target System / Therapy | Typical Non-Physiologic RTM Data Captured | 30-Day Billing & Pricing Rules |
|---|---|---|---|
| `CPT 98976` | Respiratory System | Smart inhaler actuation timestamps, inspiratory flow adherence, respiratory therapy session completion, symptom/dyspnea logs | Billable once per 30-day period; requires ≥16 days of scheduled recordings/alerts; national Medicare Physician Fee Schedule (MPFS) rate |
| `CPT 98977` | Musculoskeletal (MSK) System | Home exercise program (HEP) adherence, motion-sensor or computer-vision range-of-movement (ROM) kinematics, pain/PROM scores | Billable once per 30-day period; requires ≥16 days of scheduled recordings/alerts; national MPFS rate |
| `CPT 98978` | Cognitive Behavioral Therapy (CBT) | Prescription digital therapeutic (PDT) module completion, CBT behavioral adherence logs, patient-reported mood/symptom diaries | Billable once per 30-day period; requires ≥16 days of data transmission; Contractor-priced by regional Medicare Administrative Contractors (MACs) |
Core Device and 16-Day Transmission Requirements for `98976`, `98977`, and `98978`
- FDA Medical Device Definition (Section 201(h) of FD&C Act): The hardware sensor or Software as a Medical Device (SaMD) platform must meet the FDA definition of a medical device (not a general consumer wellness app).
- Self-Reported Data Permitted via Medical Device: Unlike RPM (`99454`), which requires automatic, non-self-reported physiological sensor readings, RTM explicitly permits patient-inputted (self-reported) non-physiologic data (such as pain ratings on a 0–10 NPRS scale or exercise completion inputs) provided the data is recorded and transmitted through an eligible medical device/SaMD.
- The Mandatory 16-Day Rule: Neither `CPT 98975` (initial setup) nor `CPT 98976`, `98977`, or `98978` (30-day device supply) may be billed if the patient records and transmits data on fewer than 16 days out of the 30-day period. Furthermore, only one device-supply code (`98976`, `98977`, or `98978`) may be billed per 30-day episode even if multiple RTM devices are supplied to the same patient.
How Do CPT 98980 (First 20 Minutes of RTM Treatment Management) and CPT 98981 (Additional 20 Minutes) Require at Least One Interactive Communication Per Calendar Month?
While the device-supply codes (`98976–98978`) run on a rolling 30-day cycle, the professional clinical time codes (cpt 98980 98981 rtm) are billed on a calendar-month basis (1st through the 30th/31st):
- `CPT 98980` (First 20 Minutes of Treatment Management): Reports the first full 20 minutes of physician or other qualified health care professional (QHP, including PT, OT, SLP, NP, PA) time in a calendar month reviewing transmitted RTM data, adjusting the therapeutic plan of care, and communicating with the patient or caregiver.
- `CPT 98981` (Each Additional 20 Minutes — Add-On Code): Listed separately in addition to `98980` when cumulative calendar-month treatment management time reaches at least 40 minutes (and for each subsequent full 20-minute increment).
- Mandatory Interactive Communication Requirement: To bill `CPT 98980` (and `98981`), the clinician or supervised therapy assistant must conduct at least one synchronous interactive communication (real-time telephone call, telehealth video call, or in-person conversation—not an asynchronous text message or portal message alone) with the patient or caregiver during the calendar month regarding the RTM data.
- No 16-Day Rule on `98980`/`98981` (Independent Time Threshold): Under AMA CPT and CMS guidelines, `CPT 98980` is governed by the 20-minute time threshold and the interactive communication requirement; if a clinician spends ≥20 minutes managing RTM data and completes the interactive call during a calendar month in which the patient transmitted data on only 12 days, `CPT 98980` is still billable even though `CPT 98977` (device supply) cannot be billed for that 30-day window.
Why Can Physical Therapists, Occupational Therapists, and SLPs Bill RTM (98975–98981) Directly When They Cannot Bill RPM (99453–99458)?
When rehabilitation directors evaluate rtm vs rpm medicare billing and ask why can Physical Therapists, Occupational Therapists, and SLPs bill RTM (98975–98981) directly when they cannot bill RPM (99453–99458), the distinction stems from where the codes reside in the CPT manual:
- RPM (`CPT 99453–99458`) Resides in the Evaluation and Management (E/M) Section: Under Medicare statute, physical therapists (PTs), occupational therapists (OTs), and speech-language pathologists (SLPs) are not eligible to bill E/M services; therefore, only physicians and non-physician practitioners (NPs, PAs, CNSs) may bill RPM.
- RTM (`CPT 98975–98981`) Resides in the General Medicine Section: CMS created RTM in the Medicine section specifically so Qualified Health Care Professionals—including PTs, OTs, and SLPs—can bill `98975–98981` directly to Medicare Part B when delivered under an established therapy Plan of Care:
- Required Therapy Modifiers: When billed by or under a therapy plan of care, RTM claims must append the appropriate discipline modifier:
GP(Physical Therapy),GO(Occupational Therapy), orGN(Speech-Language Pathology). - PTA and OTA Supervision & 15% Differential (`CQ` / `CO` Modifiers): Physical Therapist Assistants (PTAs) and Occupational Therapy Assistants (OTAs) may furnish RTM treatment management services under the supervision of a PT or OT; when more than 10% of the service is furnished by a PTA (`Modifier CQ`) or OTA (`Modifier CO`), the statutory 15% Medicare payment reduction applies.
- Prohibition on Concurrent RTM + RPM Billing: CMS prohibits billing both RTM (`98975–98981`) and RPM (`99453–99458`) for the same beneficiary in the same month across all providers.
- Required Therapy Modifiers: When billed by or under a therapy plan of care, RTM claims must append the appropriate discipline modifier:
Frequently Asked Questions
What is the difference between CPT 98976 (respiratory RTM device supply), CPT 98977 (musculoskeletal RTM device supply), and CPT 98978 (CBT device supply)?
All three are 30-day Remote Therapeutic Monitoring (RTM) device-supply codes that require an FDA-defined medical device and at least 16 days of scheduled recordings or alert transmissions per 30-day period, but each targets a specific therapeutic domain: CPT 98976 covers respiratory system monitoring (such as smart inhalers or spirometry adherence), CPT 98977 covers musculoskeletal system monitoring (such as home exercise motion sensors or digital physical therapy SaMD), and CPT 98978 covers cognitive behavioral therapy (CBT) monitoring (contractor-priced by regional MACs).
How do CPT 98980 (first 20 minutes of RTM treatment management) and CPT 98981 (additional 20 minutes) require at least one interactive communication per calendar month?
CPT 98980 reports the first full 20 minutes of clinician or supervised therapy assistant time in a calendar month reviewing RTM data and managing the treatment plan, and CPT 98981 reports each additional 20 minutes (≥40 minutes total). Both codes strictly require at least one synchronous, real-time interactive communication (phone, video, or in-person discussion) with the patient or caregiver during the calendar month.
Why can Physical Therapists, Occupational Therapists, and SLPs bill RTM (98975–98981) directly when they cannot bill RPM (99453–99458)?
Remote Physiologic Monitoring (RPM, CPT 99453–99458) codes are classified as Evaluation and Management (E/M) services, which PTs, OTs, and SLPs are statutorily barred from billing under Medicare. Remote Therapeutic Monitoring (RTM, CPT 98975–98981) codes are classified in the General Medicine section of CPT, allowing PTs, OTs, and SLPs to bill them directly under an active therapy plan of care using modifiers `GP`, `GO`, or `GN`.
