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📋 RTM RequirementsTo bill RTM under CPT codes 98975, 98976, 98977, 98980, 98981, the following elements must be met:
Use RTM when it’s medically reasonable and necessary for the condition (e.g., COPD symptom tracking, inhaler use, musculoskeletal recovery, medication adherence). The device or software used should meet the FDA definition of a medical device.
98975 is for the initial setup and patient education for the RTM device/app (paraphrased).
98976 covers device/app supply and monitoring for respiratory status per 30 days (paraphrased).
98977 covers device/app supply and monitoring for musculoskeletal status per 30 days (paraphrased).
98980 accounts for the first 20 minutes per calendar month of treatment management time, including required interaction with the patient/caregiver (paraphrased).
+98981 is billed for each additional 20 minutes (paraphrased).
For 98980/98981, each month must include at least one real-time, two-way interactive communication with the patient or caregiver (e.g., a live phone call, a telehealth/video visit, or secure messaging with immediate back-and-forth). One-way device data, automated alerts, or educational materials without a reply do not meet this requirement by themselves.
Record the device/app type, condition monitored, patient education/setup details, the treatment plan, time spent, and evidence of the interactive communication (date, modality, substance).
RTM and RPM should not be billed together for the same patient/condition in the same month. When appropriate, clinical staff time may be furnished under general supervision according to CMS rules.
98976/98977 are billed per 30 days.
98980/98981 are billed monthly based on time (first 20 minutes, then each additional 20 minutes).
✅ Quick Takeaway
RTM enables providers to bill for digital monitoring of therapeutic data (non‑physiologic) such as medication adherence, musculoskeletal recovery, or respiratory symptoms. To stay compliant:
RTM ensures clinicians are reimbursed for leveraging digital health tools to support patient adherence, therapy engagement, and clinical outcomes outside traditional visits.
