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Remote Therapeutic Monitoring (RTM) is a category of digital health services established by the Centers for Medicare & Medicaid Services (CMS) in the Calendar Year (CY) 2022 Medicare Physician Fee Schedule (MPFS) Final Rule (`86 FR 64996`) that enables clinicians—including Physical Therapists (PTs), Occupational Therapists (OTs), Speech-Language Pathologists (SLPs), physicians, and non-physician practitioners—to monitor non-physiologic health data related to a patient’s musculoskeletal system status, respiratory system status, cognitive behavioral therapy (CBT), therapy adherence, and therapy response using an FDA-defined medical device (including Software as a Medical Device [SaMD]).
Whereas Remote Physiologic Monitoring (RPM, CPT 99453–99458) is restricted to automatically synced physiologic vital signs (such as blood pressure, heart rate, blood glucose, or SpO2) billed only by physicians and E/M-eligible Qualified Healthcare Professionals (QHPs), Remote Therapeutic Monitoring (CPT 98975–98981) captures functional, symptom, and adherence data—including patient self-reported pain scores, home exercise program (HEP) completion, and validated Patient-Reported Outcome Measures (PROMs)—and opens Medicare remote monitoring reimbursement directly to rehabilitation therapists.
What Is Remote Therapeutic Monitoring? The Complete RTM CPT Code Set (98975–98981)
The AMA CPT Editorial Panel and CMS structure Remote Therapeutic Monitoring into two code categories: (1) Practice Expense (PE) Education & Device Supply Codes (CPT 98975, 98976, 98977, 98978) and (2) Professional Treatment Management Time Codes (CPT 98980 and 98981), plus HCPCS G0511 for Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs):
| CPT / HCPCS Code | Official Code Descriptor & Organ System | Billing Frequency & Minimum Data / Time Threshold | Key CMS Compliance Rules |
|---|---|---|---|
CPT 98975 |
Initial Set-Up and Patient Education on use of RTM equipment. | Billed once per episode of care, only after at least 16 days of data have been collected (updated to align with supply thresholds, withAMA/CMS updates introducing shorter-window codes in later cycles). | Covers onboarding the patient onto the RTM sensor or SaMD mobile app and verifying first transmission. |
CPT 98976 |
Respiratory System Device Supply with scheduled recording(s) and/or programmed alert(s) transmission, each 30 days. | Billed once per 30-day period; requires at least 16 days of scheduled recordings/transmissions within the 30-day window. | Used for smart inhaler adherence sensors (COPD/asthma), digital spirometry/peak flow adherence, and respiratory therapy response. |
CPT 98977 |
Musculoskeletal (MSK) System Device Supply with scheduled recording(s) and/or programmed alert(s) transmission, each 30 days. | Billed once per 30-day period; requires at least 16 days of scheduled recordings/transmissions within the 30-day window. | Used by orthopedic clinics and physical/occupational therapy practices deploying inertial motion sensors, computer-vision HEP apps, and MSK pain/PROM tracking (such as Limber Health or Sword Health). |
CPT 98978 |
Cognitive Behavioral Therapy (CBT) Device Supply with scheduled recording(s) and/or programmed alert(s) transmission, each 30 days. | Once per 30-day period (≥16 days of data). | Assigned Contractor Priced status by Medicare Administrative Contractors (MACs) for FDA-cleared prescription digital therapeutics (PDTs) delivering CBT. |
CPT 98980 |
RTM Treatment Management Services, physician or other qualified healthcare professional time in a calendar month requiring at least 1 interactive communication with the patient or caregiver during the calendar month; first 20 minutes. | Billed once per calendar month when cumulative clinical review and management time reaches ≥20 minutes (plus ≥1 synchronous phone/video/in-person communication). | Unlike device supply codes (`98976`/`98977`), CMS confirmed that 98980 does not require 16 days of device transmission to be billed in a calendar month if the 20-minute clinical management and interactive communication criteria are met. |
CPT 98981 |
RTM Treatment Management Services (Add-On); each additional 20 minutes per calendar month. | Billed alongside primary code 98980 when cumulative monthly time reaches ≥40 minutes (1 unit) or ≥60 minutes (2 units). |
Requires documented time logs distinguishing asynchronous dashboard review from synchronous interactive communication. |
Which Is True for Remote Therapeutic Monitoring? (5 Core Regulatory Facts)
In medical coding certification exams, compliance audits, and clinical implementation reviews, clinicians frequently encounter the question “Which is true for Remote Therapeutic Monitoring?” Under official CMS MPFS rulemaking and AMA CPT guidelines, five regulatory distinctions define RTM:
- Patient Self-Reported Data Is Explicitly Permitted (Unlike RPM): For Remote Physiologic Monitoring (`CPT 99453–99458`), vital signs must be automatically measured and synced by hardware without manual patient typing. For Remote Therapeutic Monitoring (`CPT 98975–98981`), CMS explicitly ruled that therapeutic data (such as numeric pain scale ratings, home exercise adherence logs, medication inhaler actuation feedback, or functional disability scores like the Oswestry Disability Index [ODI]) can be self-reported and manually entered by the patient into an FDA-defined Software as a Medical Device (SaMD) platform, as well as objectively captured by wearable sensors.
- The Software or Hardware Must Meet the Federal Food, Drug, and Cosmetic (FD&C) Act Section 201(h) Definition of a Medical Device: Even when an RTM platform is pure software (a mobile app or web portal), it cannot be a generic consumer survey tool; it must qualify as a medical device under Section 201(h) of the FD&C Act (whether FDA 510(k)-cleared, De Novo-authorized, or 510(k)-exempt / enforcement-discretion SaMD).
- Physical Therapists (PTs), Occupational Therapists (OTs), and Speech-Language Pathologists (SLPs) Can Bill RTM Directly: Because CPT placed the RTM code family (`98975–98981`) in the Medicine section rather than the Evaluation and Management (E/M) section, rehabilitation therapists in private practice and institutional settings can bill RTM directly using therapy plan-of-care modifiers
GP(Physical Therapy),GO(Occupational Therapy), orGN(Speech-Language Pathology). - PTA and OTA General Supervision Rules Apply in Private Practice: Under CMS CY 2023 and CY 2024 MPFS updates, Physical Therapist Assistants (PTAs) and Occupational Therapy Assistants (OTAs) may furnish RTM services under the general supervision of the billing PT or OT (Note: when more than 10% of a therapy service is furnished by a PTA or OTA, the claim must append modifier
CQ[PTA] orCO[OTA]). - RTM and RPM Cannot Be Billed Together in the Same Month for the Same Patient: CMS prohibits billing both RTM treatment management (`98980`/`98981`) and RPM treatment management (`99457`/`99458`)—or both RTM and RPM device supply codes—for the same beneficiary in the same calendar month/30-day period to prevent duplicative device and time payments. However, RTM can be billed in the same month as Chronic Care Management (`CPT 99490`) provided clinical minutes are never double-counted.
Remote Therapeutic Monitoring (RTM) vs. Remote Physiologic Monitoring (RPM) Compared
| Comparison Dimension | Remote Therapeutic Monitoring (RTM) | Remote Physiologic Monitoring (RPM) |
|---|---|---|
| CPT Code Family | 98975, 98976, 98977, 98978, 98980, 98981 (CPT Medicine section). |
99453, 99454, 99457, 99458 (plus 99091; CPT Evaluation & Management section). |
| Nature of Monitored Data | Non-physiologic therapeutic data: MSK range of motion, home exercise adherence, pain severity, PROMs, respiratory inhaler adherence, CBT engagement. | Physiologic parameters: Blood pressure, heart rate, pulse oximetry (SpO2), blood glucose, body weight, core temperature, ECG. |
| Patient Self-Reported Input | Permitted (when entered into an FD&C Act § 201(h) medical device / SaMD). | Not permitted (data must be automatically measured and electronically transmitted by the sensor). |
| Eligible Billing Practitioners | Physicians (MD/DO), NP, PA, CNS, CNM, Physical Therapists (PT), Occupational Therapists (OT), Speech-Language Pathologists (SLP), and clinical psychologists. | Restricted to Physicians (MD/DO) and QHPs eligible to bill Medicare E/M services (NP, PA, CNS, CNM). |
| Device Supply Organ-System Specificity | Organ-system specific: 98976 (Respiratory), 98977 (Musculoskeletal), 98978 (Cognitive Behavioral Therapy). |
Organ-system agnostic: 99454 covers any qualifying physiologic medical device. |
Frequently Asked Questions
What is Remote Therapeutic Monitoring (RTM)?
Remote Therapeutic Monitoring (RTM) is a CMS-reimbursed digital health framework (CPT codes 98975–98981) that tracks non-physiologic therapeutic data—specifically musculoskeletal status, respiratory status, cognitive behavioral therapy, medication/exercise adherence, and pain or functional response—using an FDA-defined hardware or software medical device (SaMD), allowing both physicians and rehabilitation therapists (PTs, OTs, SLPs) to manage patients remotely between clinic visits.
Which is true for Remote Therapeutic Monitoring?
Under CMS Medicare Physician Fee Schedule rules, five key principles are true for Remote Therapeutic Monitoring: (1) it monitors non-physiologic therapeutic data rather than vital signs, (2) patients may manually self-report pain, symptom, and adherence data into an FDA-defined SaMD or medical device, (3) Physical Therapists (GP), Occupational Therapists (GO), and Speech-Language Pathologists (GN) can bill RTM directly, (4) device supply codes 98976 and 98977 require at least 16 days of data transmission per 30-day period, and (5) RTM cannot be billed concurrently with Remote Physiologic Monitoring (RPM) for the same patient in the same month.
