RTM Billing: The Revenue You're Leaving on the Table

$120–150 per eligible patient per month. CPT codes finalized in 2022. Reimbursement available across commercial payers and Medicare. Most practices that qualify are not billing correctly — or not billing at all.

Remote Therapeutic Monitoring (RTM) is one of the most underutilized revenue opportunities in outpatient medicine. Here’s what you need to know.

What Is RTM — And How Is It Different From RPM?

RTM stands for Remote Therapeutic Monitoring. It covers monitoring of therapeutic adherence and outcomes for musculoskeletal, respiratory, and cognitive behavioral conditions.

It is not the same as Remote Patient Monitoring (RPM), which requires physiological measurement devices — blood pressure cuffs, glucometers, pulse oximeters. RPM (CPT 99453–99458) is device-dependent. RTM is not. RTM can be delivered through patient-reported outcomes, software-based tracking, and clinical staff engagement — no hardware required.

This distinction matters because many practices assumed RTM required device investment and dismissed it. It doesn’t. If you’re already checking in on patients between visits, tracking adherence to therapy programs, or documenting patient-reported outcomes, you may already be doing the clinical work without the billing.

The RTM CPT Codes

• CPT 98975 — Remote therapeutic monitoring setup and patient education. Billed once per episode of care. This covers onboarding the patient to the monitoring program.
• CPT 98976 — Device supply with scheduled (e.g., daily) recording for respiratory system. Monthly supply code.
• CPT 98977 — Device supply with scheduled recording for musculoskeletal system. Monthly supply code. This is the most commonly applicable code for PT, ortho, and pain management practices.
• CPT 98980 — Treatment management services, first 20 minutes of clinical staff time per calendar month. This is the primary ongoing billing code — requires 20 minutes documented per month per patient.
• CPT 98981 — Treatment management services, each additional 20 minutes per calendar month. Can be billed in addition to 98980 when time is documented.

98980 and 98981 require a physician or NPP to review and participate in management — but the 20 minutes can be accumulated by clinical staff (including MAs and nurses) under general supervision.

Who Qualifies

RTM is applicable across a wide range of outpatient specialties. Eligible patient populations include:

• Musculoskeletal patients — physical therapy, orthopedics, pain management, sports medicine
• Respiratory patients — pulmonology, primary care managing COPD or asthma, sleep medicine
• Cognitive behavioral therapy patients — psychiatry, psychology, behavioral health
• Addiction medicine patients on medication-assisted treatment (MAT) — adherence monitoring qualifies
• Post-surgical patients requiring therapeutic monitoring during recovery

The threshold for eligibility is lower than most practices assume. If you have a clinical reason to monitor therapeutic adherence between visits, and you’re documenting that monitoring, you likely qualify.

The Math

Reimbursement rates vary by payer and geography, but typical combined monthly revenue per enrolled patient (98977 + 98980) runs $120–150 under Medicare and comparable commercial rates.

• 25 enrolled patients: $3,000–3,750/month
• 50 enrolled patients: $6,000–7,500/month
• 100 enrolled patients: $12,000–15,000/month
• 200 enrolled patients: $24,000–30,000/month

This is revenue on top of existing visit-based billing. You’re not replacing a revenue stream — you’re adding one for care you’re already delivering.

Common Billing Questions

Can I bill 98980 and 98981 in the same month? Yes — if you document time for both thresholds. First 20 minutes = 98980. Each additional 20 minutes = 98981. Document timestamps.

Can non-physicians bill RTM? Yes. Nurse practitioners and physician assistants can bill under their own NPI with general physician supervision. Clinical staff time counts toward the 20-minute threshold.

Does the patient need a physical device? Not necessarily. RTM covers software-based monitoring and patient-reported outcomes. A patient completing a digital pain scale or adherence questionnaire can qualify.

Is RTM compatible with telehealth billing? Yes. RTM and telehealth are separate billing events and can coexist in the same month.

Implementation Steps

Getting RTM billing operational is a process, not a weekend project. Here’s the sequence that works:

1. Identify eligible patients in your current panel — start with musculoskeletal and respiratory if you have them.
2. Enroll patients with documented consent and bill 98975 for setup. One per episode.
3. Establish a monthly monitoring workflow — who touches the patient record, what they document, how time is recorded.
4. Bill 98977 (or 98976) monthly for the supply component.
5. Bill 98980 when 20 minutes of clinical staff time is documented. Add 98981 if you reach the second 20 minutes.
6. Audit quarterly — review documentation, confirm billing accuracy, check denial rates by payer.

The biggest implementation risk is inconsistent documentation. Time logs must be specific — start time, end time, type of activity. “20 minutes of RTM” without timestamps doesn’t hold up to audit.

Payer Coverage in 2026

Medicare covers the full RTM code set under the Medicare Physician Fee Schedule, with reimbursement rates that are geographically adjusted but generally run $19 for 98975 (setup, one-time), $45 to $55 for the device supply codes (98976, 98977), approximately $48 to $62 for 98980 (first 20 minutes treatment management), and approximately $38 to $45 for 98981 (each additional 20 minutes). The combination of 98977 and 98980 generates the baseline monthly RTM revenue of $100 to $130 per patient under Medicare, with 98981 adding another $38 to $45 in months where additional management time is documented.

Commercial payer coverage has expanded substantially since RTM codes were introduced in 2022. Major payers with published RTM coverage policies as of 2026 include Aetna, UnitedHealthcare, Cigna, and most regional Blue Cross Blue Shield plans. Coverage specifics — prior authorization requirements, covered diagnoses, covered provider types — vary at the plan level and should be verified before enrolling commercial patients. Practices in states with strong BCBS market penetration should check their specific BCBS plan’s policy, as coverage can differ significantly between states under the same BCBS brand.

A small but growing number of Medicaid managed care plans cover RTM, particularly in states that have adopted value-based care programs. Medicaid coverage for RTM is the most variable of the three payer categories and requires direct verification with each managed care plan. It is worth checking annually, as Medicaid RTM coverage has been expanding consistently since 2023.

Who Can Bill RTM

An important and often misunderstood aspect of RTM billing is the range of provider types that can bill under their own NPI. Unlike some remote monitoring codes that are restricted to physicians and advanced practice providers, the RTM code set can be billed by:

• Physicians and non-physician practitioners (NPs, PAs) under the standard supervision requirements
• Physical therapists billing under their own NPI for musculoskeletal RTM (CPT 98977)
• Occupational therapists billing under their own NPI for musculoskeletal RTM
• Speech-language pathologists billing under their own NPI for applicable RTM services
• Licensed clinical social workers and other behavioral health providers for CPT 98978

This is a significant expansion of billable provider types compared to RPM, which is largely restricted to physician billing. Physical therapy and occupational therapy practices are among the biggest beneficiaries of RTM because they have large panels of musculoskeletal patients and can bill independently without physician oversight for the clinical management component.

The 16-Day Compliance Requirement in Practice

The 16-day data collection threshold — patients must transmit monitoring data on at least 16 of the 30 days in the billing period — is the most frequently cited source of RTM billing problems. In theory, it is a straightforward compliance requirement. In practice, maintaining 16-day thresholds across a panel of 30 to 100 patients requires active monitoring and patient engagement.

Patient engagement with monitoring tools follows a predictable curve: high in the first week or two, tapering in weeks three and four as the novelty wears off. A patient who logs daily in week one and every other day in week two may reach day 20 with only 11 to 12 days of data logged — well short of the 16-day threshold. Without an active re-engagement effort, that patient does not generate billable 98977 revenue for the month.

Practices that build patient engagement workflows — a check-in message when a patient falls behind on logging, a brief reminder call when a patient is on track to miss the threshold — maintain 16-day compliance rates of 85 to 90 percent across their enrolled panels. Practices that do not typically see compliance rates of 60 to 70 percent, losing 30 to 40 percent of potential device supply revenue to patients who were enrolled but not meeting the threshold.

RTM as a Clinical Quality Improvement Tool

The financial case for RTM is compelling, but practices that implement it primarily as a billing optimization tend to have lower patient engagement and higher dropout rates than practices that lead with the clinical value. The practices with the strongest RTM programs are those where the clinical team genuinely uses the monitoring data to manage patients between visits — catching trends early, reaching out when data signals concern, and adjusting treatment plans based on between-visit information rather than waiting for the next scheduled appointment.

When patients perceive that their monitoring data is actually being read and responded to — that a staff member notices when their pain scores increase and follows up — their engagement with the monitoring program is substantially higher than when they perceive it as a passive data collection exercise. The clinical engagement is what sustains the enrollment retention that makes RTM revenue consistent over months and years rather than declining as patients disengage.

The practices that run RTM well are running a better clinical program alongside a better billing program. The financial and clinical outcomes reinforce each other. Better between-visit data leads to better clinical decisions, which leads to better patient outcomes, which leads to more engaged patients who maintain their monitoring and generate consistent RTM revenue. The billing opportunity and the clinical opportunity are the same opportunity.