AI and Remote Therapeutic Monitoring: Where the Two Actually Intersect

August 29, 2026

TL;DR

  • AI inside current RTM workflows usually applies rules to structured activity and time data. It does not generate clinical judgments or predict patient outcomes.
  • RTM automation logs qualifying patient activity, counts monitored days, tallies clinician treatment-management minutes, and alerts clinicians when billing thresholds are met.
  • RTM software can assemble supporting evidence before claim review, but a licensed clinician should confirm every billing code.
  • Clinic owners should examine “AI-powered RTM” claims carefully. Reliable software shows the underlying activity, threshold calculation, and documentation that support each code.
  • RTM refers to a US Medicare billing mechanism, and automation does not guarantee payment or compliance.

What "AI" actually means inside RTM

Inside RTM, software usually handles rules-based tracking tied to billing thresholds and documentation, even when a vendor calls the product AI. The broader physical therapy AI category covers ambient note generation and exercise search. Computer vision tools also estimate patient movement. None of those methods defines the automation needed for a US Medicare RTM workflow.

RTM automation turns patient and clinician activity into structured evidence for review. When a patient completes a qualifying activity, the software logs the monitored day against the applicable billing window. As recorded-day counts or treatment-management minute totals reach a configured threshold, the software alerts the clinician before the window closes. During review, the platform assembles activity records, management-time records, and related documentation so the clinician can check the evidence.

An “AI-powered RTM” label does not identify the underlying mechanism. One vendor may use the phrase for a generative model or predictive scoring. Another may use it for threshold rules and structured-data automation. Clinic owners should ask what the software actually records, calculates, and presents for review.

Threshold automation can reduce manual counting, but it should not make autonomous billing decisions. A licensed clinician should review the supporting evidence and confirm every billing code.

The CPT codes that automation tracks

RTM automation tracks CPT thresholds across different billing periods. Device-supply codes use 30-day periods, while treatment-management codes use calendar months. Each code covers a different part of setup, device supply, or treatment management, so software must keep the underlying activity and time records separate.

CPT 98975 covers initial device setup and patient education once per episode of care. Automation can record enrollment and setup completion, but a clinician must verify that the required work occurred.

Device-supply codes depend on monitored days. CPT 98980 applies when a patient records qualifying activity on 2 to 15 days within a 30-day period, while CPT 98981 applies when activity is recorded on 16 or more days within that period. A monitored day requires the patient to complete at least one activity in the app. Opening a link or viewing a PDF does not qualify by itself.

Treatment-management codes depend on clinician time and require at least one real-time, synchronous interaction with the patient during the applicable period. A phone or video conversation can meet that interaction requirement when the service satisfies the applicable billing rules. Asynchronous review alone does not. Practices should confirm the current treatment-management code numbers and minute thresholds with their billing and compliance teams, since code assignments are periodically updated by CMS.

Remote therapeutic monitoring software can count qualifying days, total recorded management minutes, and flag when a threshold has been reached. Reaching a numerical threshold does not establish billing eligibility on its own. A licensed clinician still needs to review the record and confirm that every requirement for the selected code was met.

RTM is a US Medicare mechanism tied to CPT codes. Other countries may use remote monitoring in clinical care, but they do not automatically share the same RTM billing category or code requirements. Practices should confirm coding decisions with their billing and compliance teams.

Where manual tracking breaks down at scale

Using the thresholds defined above, a clinic must maintain separate running counts for every enrolled patient. Staff must count qualifying activity days within each patient’s 30-day window and track treatment-management minutes during the applicable month. A spreadsheet may handle a small census, but higher volume creates repeated date checks, late entries, and unclear ownership.

Manual day counting often fails near the end of a billing window. A clinician may see regular app use but overlook which dates included qualifying activity. Staff may also count a link view that does not qualify. The clinic can then miss an eligible threshold or treat an unsupported count as complete.

Interaction minutes create a second reconciliation problem. Clinicians may record synchronous calls in different places, round time inconsistently, or enter time after the fact. Across a full patient census, those habits can lead to undercounted minutes and inconsistent records across the clinic.

Automation can attach real patient activity to the correct 30-day window and maintain current minute totals from clinician entries. Threshold alerts give staff time to review the evidence before a billing window closes. Software surfaces the counts and supporting records, while a licensed clinician decides whether the documentation supports a code.

Why a clinician still confirms every code

Automation should prepare an RTM billing review, while a licensed clinician confirms every code. Software can count monitored days, total recorded management time, and flag when a patient crosses a threshold. A threshold crossing alone does not establish that every billing requirement was met.

The clinician must review the underlying evidence and confirm that the recorded activity qualifies. The review should also verify required real-time interaction, applicable documentation, and any patient-specific eligibility requirements. Software cannot independently judge medical necessity or resolve incomplete and conflicting records with the accountability expected of a clinician.

CMS scrutiny of remote monitoring billing makes an auditable review process especially important. An RTM platform should preserve activity records, time entries, and threshold calculations so the clinician can see why a code became eligible for review. Software that submits codes autonomously removes the professional checkpoint and can turn a tracking error into an unsupported claim.

Proposed CMS changes for CY2027 have not been finalized. The proposals may affect patient eligibility, initiating visits, staffing requirements, and the code structure, but practices should not change their workflows based on assumed outcomes. Clinic owners should confirm current requirements with their billing and compliance teams.

A defensible RTM workflow assigns each actor a specific role. Software collects and organizes evidence. The licensed clinician reviews that evidence and confirms the code before billing.

How Physitrack's RTM tooling applies this model

Physitrack applies structured automation throughout its current RTM workflow. An enrollment-status indicator shows which patients are participating, while automatic activity logging records a monitored day when a patient completes at least one activity in PhysiApp. Opening a link or PDF does not create a qualifying activity record.

Physitrack also helps clinicians track the criteria that are difficult to manage manually. A clinician timer records treatment management time, and threshold alerts identify patients who have met relevant monitored-day or time thresholds. Clinicians can add manual entries when necessary rather than relying on a separate spreadsheet or retrospective count.

The Review RTM step assembles activity records, clinician time, and supporting evidence for review. A licensed clinician then checks the evidence and confirms each billing code. Physitrack does not make the billing decision autonomously.

Physitrack offers one example of an automation-plus-confirmation model. Its RTM capabilities operate outside the Raintree chart today, so clinics should evaluate how the workflow fits their existing documentation and billing systems.

A framework for evaluating any RTM platform's automation claims

Evaluate RTM automation by asking vendors to demonstrate four specific capabilities.

  1. Does the platform count real patient activity as monitored days? Opening a link or viewing a PDF should not qualify. The platform should record a monitored day only when the patient completes qualifying activity.

  2. Does the platform flag threshold crossings before the billing window closes? Alerts should give clinicians time to review monitored-day counts and recorded management minutes within the applicable period.

  3. Does the platform assemble evidence that supports an audit? A useful record connects qualifying activity with dates and shows recorded management time. The record should also document required real-time interactions and any manual entries.

  4. Does a licensed clinician confirm every billing code? Software can surface thresholds and organize supporting evidence, but it should not make an autonomous billing decision. The clinic’s billing and compliance teams should verify that the workflow meets current requirements.

Physitrack provides one example of this model. Physitrack tracks enrollment and qualifying patient activity automatically. Its clinician timer records management minutes, while threshold alerts identify patients ready for review. The Review RTM step then assembles the available evidence before a clinician confirms the code.

RTM automation should handle administrative tracking and evidence assembly. A licensed clinician should retain the billing decision.

FAQs

Does RTM exist outside the US?

RTM is a US Medicare billing mechanism tied to CPT codes. Physitrack supports remote monitoring in other countries, but those services do not become US-style RTM claims. Clinics outside the US should use local reimbursement rules.

Does opening a link or PDF count as a monitored day?

A monitored day requires the patient to complete at least one activity in the app. Physitrack records qualifying patient activity rather than counting link or PDF access. Activity-based records give clinicians clearer evidence for code review.

Who is responsible for confirming the billing code?

The licensed clinician and the practice’s billing team remain responsible for each submitted code. Physitrack assembles evidence and flags thresholds, but the clinician confirms the code. Human confirmation keeps the billing decision with the accountable professional.

What happens if monitored-day counts are wrong?

Incorrect counts can produce a missed billing opportunity or an unsupported claim. Physitrack’s activity logs and Review RTM step help clinicians check the underlying evidence before submission. Practices should resolve discrepancies and confirm billing requirements with their compliance teams.

Kevin Kaminyar
Global Head of Growth