RTM Billing Codes for PT, OT, and SLP: A Complete Guide to CPT Codes, Documentation, and Compliance

TL;DR

• Five RTM CPT codes apply to therapy practices. The codes 98975 (setup), 98976 (respiratory device), 98977 (musculoskeletal device), 98980 (treatment management), and 98981 (add-on) cover the program (tenovi.com).
• Device codes pay roughly $43 per 30 days and require at least 16 days of data; treatment management starts at about $50 for the first 20 minutes (tenovi.com).
• PTs, OTs, and SLPs qualify to bill when services run under a therapy plan of care with a GP, GO, or GN modifier (blog.nsightcare.com).
• A missing modifier, no interactive communication, or concurrent RPM billing triggers most denials.
• Only one clinician may bill per patient per 30-day period.

What Remote Therapeutic Monitoring Is: Why It Matters for PT, OT, and SLP Practices

Remote Therapeutic Monitoring reimburses clinicians for reviewing and managing non-physiological patient data collected through a medical device between visits. Therapy adherence, pain levels, range of motion, and functional status all qualify as the kind of data RTM tracks (thoroughcare.net). A patient logging home exercise compliance through a software application generates exactly the data RTM was built to capture.

The data type is what separates RTM from Remote Patient Monitoring, and that distinction decides whether you can bill at all. RPM covers physiological measurements like blood pressure, weight, and glucose, and its eligible provider list excludes therapists (thoroughcare.net). RTM opened the eligible-biller list to physical therapists, occupational therapists, and speech-language pathologists alongside physicians, nurse practitioners, and physician assistants. If you run a PT, OT, or SLP practice, RTM is the monitoring pathway you can actually submit claims under.

That eligibility carries a real financial case. The five RTM codes pay for work many practices already do informally, namely setting up a patient with a home program, watching their adherence, and managing their treatment based on what the data shows. CPT 98980 alone reimburses roughly $50 for the first 20 minutes of treatment management in a calendar month, with an add-on code for each additional 20 minutes (tenovi.com). For a practice monitoring dozens of patients between visits, the monthly totals add up.

CMS introduced RTM in 2022, and the codes remain on the agency's New Technology List through April 2030 (blog.nsightcare.com). That timeline gives you a stable reimbursement horizon to build a program around rather than a pilot that might disappear next fiscal year.

The rest of this guide moves from definition to execution. We walk through each CPT code and its threshold, the documentation that supports a clean claim, the denial patterns that catch practices off guard, and the workflow that lets an RTM program scale without burying your staff in manual logs.

The Five Core RTM CPT Codes: What Each One Covers

The five original RTM codes split into two functions. Three codes (98975, 98976, and 98977) cover device supply and setup, paying for the equipment and education that get a patient monitoring at home. Two codes (98980 and 98981) cover treatment management, paying for the clinician time spent reviewing data and communicating with the patient. CMS sets a national average rate for each, though those figures shift with the annual Physician Fee Schedule and the 2026 rule lowered the day and minute thresholds with three new companion codes. The sections below break down each code, its threshold, and its 2025 rate so you can match them to your own caseload.

CPT 98975: Initial Setup and Patient Education

CPT 98975 pays for the work of getting a patient onto an RTM device and teaching them how to use it. You bill it once per episode of care, not monthly, so it covers the one-time setup at the start of a monitoring program. The code captures device configuration and the patient education that makes adherence data reliable, including how to record exercises and transmit results.

The 16-day data threshold gates the claim. Before you can submit 98975, the patient must collect data on at least one medical device for a minimum of 16 days within a 30-day window (tenovi.com). A setup without that minimum collection does not support the code, even when the education was thorough.

The national non-facility average runs around $20 to $22, with the 2025 rate at $19.73 (tenovi.com). Your setup documentation should record the device type, the education you provided, the data-input instructions, and the prescribed exercise frequency (blog.nsightcare.com). Those four elements are what an auditor checks when 98975 appears on a claim.

CPT 98976: Respiratory System Device Supply

CPT 98976 covers the supply of a device that monitors a patient's respiratory system through scheduled recordings or programmed alert transmissions. You bill it once per 30-day episode of care, and the same 16-day threshold that governs the other device codes applies. The patient must record or transmit data on at least one medical device for a minimum of 16 days within the 30-day window. The 2025 national non-facility average pays around $43.

Most respiratory RTM activity concerns SLP practices managing patients with conditions affecting breathing and voice, though it also fits pulmonary rehabilitation programs. The software application a patient uses to log adherence and symptoms qualifies as the device, so SLPs do not need separate hardware to bill it.

Starting in 2026, CMS added CPT 98984 as a lower-threshold companion to 98976. The new code covers respiratory device supply for 2 to 15 days of data instead of 16 or more, paying roughly $40 (Nsight Health). If a patient transmits data on fewer than 16 days in a period, you bill 98984 rather than losing the claim entirely.

CPT 98977: Musculoskeletal System Device Supply

CPT 98977 is the device supply code most PT and OT practices will bill, because it covers musculoskeletal monitoring. The code reimburses the supply of an FDA-defined device that captures scheduled recordings or programmed alerts to track the musculoskeletal system, including therapy adherence, pain, and range of motion. You bill it once per 30-day episode of care at roughly $43 to $51 national average, depending on the year and your geography (tenovi.com).

Two rules cause most denials on this code. First, you need at least 16 days of data collected on at least one device within the 30-day period before the claim qualifies. A patient who logs only 12 days does not meet the threshold, and the claim will be rejected.

Second, only one clinician may bill 98977 per patient per 30-day period. If two providers submit claims, the payer reimburses the first received and denies the rest (blog.nsightcare.com).

For 2026, 98977 is also mutually exclusive with the new lower-threshold code 98985 in the same 30-day period. Bill one MSK device code, never both.

CPT 98980: Treatment Management, First 20 Minutes

CPT 98980 pays for the time you spend managing a patient's treatment based on the data their device transmits. To bill it, you must log at least 20 minutes of management time in a calendar month and conduct at least one interactive communication with the patient or caregiver by phone or video during that month. The 2025 national non-facility average is $50.14. Without that live conversation on record, the time you logged does not support a claim.

The billing period for 98980 is the calendar month, and that timing differs from the device codes. CPT 98975, 98976, and 98977 bill against a 30-day episode of care, while 98980 and 98981 bill against the calendar month. Those two clocks rarely start on the same day, and practices that assume they align submit claims with the wrong dates of service. When you treat a single 30-day window as covering both your setup and your management time, you invite a denial.

Supervision rules for assistants differ between RTM tiers. PTAs and OTAs may contribute to the management time counted toward 98980, but only under the direct supervision of the supervising PT or OT, meaning the billing clinician is in the same office location. CQ and CO modifier rules apply to that assistant-furnished time. When PTs, OTs, or SLPs bill 98980, the service must sit under a therapy plan of care and carry a GP, GO, or GN modifier.

CPT 98981: Treatment Management, Each Additional 20 Minutes

CPT 98981 covers each additional 20-minute block of RTM treatment management within a calendar month, billed on top of the first 20 minutes. It carries the same requirements as 98980, including at least one interactive communication with the patient or caregiver during the month and an actual time log meeting each 20-minute increment (Nsight Health). The 2025 national average sits near $39 per unit, and you can report 98981 multiple times when documented minutes support it.

The hard rule is that 98981 stacks only on 98980. The 2026 Physician Fee Schedule added 98979, a treatment management code for the first 10 minutes that lets you bill below the 20-minute floor (Nsight Health). Attaching 98981 to 98979 triggers a denial every time, because the add-on belongs only to the 20-minute base code. If your monthly management time reaches 20 minutes, bill 98980 and stack 98981 from there. If it lands between 10 and 20 minutes, bill 98979 alone and report no add-on.

RTM vs. RPM: The Differences That Determine What You Can Bill

RTM and Remote Patient Monitoring (RPM) share a similar structure, but they monitor different things and admit different clinicians, and those two facts decide whether a PT, OT, or SLP can bill at all. RTM covers non-physiological data such as therapy adherence, functional status, pain levels, and range of motion. RPM covers physiological data such as blood pressure, weight, glucose, and oxygen saturation. Because therapy outcomes are non-physiological, RTM is the pathway that opens to therapy disciplines.

The provider lists follow from that distinction. RTM admits physicians, nurse practitioners, physician assistants, and PTs, OTs, and SLPs. RPM admits physicians, NPs, PAs, and clinical nurse specialists, but not therapists (thoroughcare.net). If you run a PT, OT, or SLP practice, RTM is your code set and RPM is not.

The table below makes the full comparison scannable.

One rule governs the relationship between the two programs. You cannot bill RTM and RPM for the same patient in the same month (blog.nsightcare.com). When a patient could plausibly qualify for both, pick the program that matches the data you actually collect, and bill it cleanly rather than splitting monitoring across both.

Documentation Requirements for a Compliant RTM Claim

A compliant RTM claim rests on five records that must exist before and during monitoring, not after a payer requests them. Build each one into your workflow as a gate, because an audit reviews the documentation that existed at the time of service, not the version you assemble in response to a denial.

Patient consent

Document consent before any monitoring begins. CMS permits verbal or written consent, but written consent gives you substantially stronger protection if a claim is reviewed (ccnhealth.com). The record must capture four things. The patient agreed to participate, only one clinician will bill RTM per period, the patient understands any cost-sharing obligation, and the patient may revoke at any time. If you rely on verbal consent, note the date, who obtained it, and a summary of what was disclosed. Refresh consent annually or whenever the program changes. The most common failure is enrolling a patient and starting monitoring while consent paperwork catches up later, which creates retroactive exposure on every claim filed in the gap.

Device setup records

Record device provisioning per patient with the assignment date, device type, and serial number, plus a note that you educated the patient on how to use it. Keep a device inventory that tracks assignment, status, and replacement history, and hold the device specifications and FDA clearance documentation on file. These records prove the monitoring data came from a qualifying device rather than an unverified source.

Transmission logs

Track transmission day counts throughout each billing period and retain a monthly log showing daily reading counts. Every device supply code requires at least 16 days of data within the period, so a mid-period check matters more than an end-of-period count. Review active patients around the halfway mark to identify anyone trending below 16 days while you still have time to intervene. A patient who reaches day 20 with 9 transmissions cannot recover the threshold.

Clinician review notes

Every entry needs the date of service and a legible, dated, timed signature. The faster failure is cloned documentation, meaning entries that copy forward across patients or visits without updating for the current encounter. Auditors treat cloned notes as grounds for denial and recoupment of prior payments (myhealthtoolkitma.com). Each note must reflect what you actually observed and decided for that specific patient on that specific day.

Time tracking

Document actual minutes, not units. For time-based codes, the record must show the number of minutes or begin-to-end times, and documentation expressed in units is denied outright (myhealthtoolkitma.com). If you log a range such as "20 to 30 minutes," a reviewer credits only the lowest number. Every entry needs four elements. The date, the duration in minutes, a description of the activity, and the identity of the clinical staff member who performed it.

The difference between a paid and denied 98980 claim usually comes down to specificity in this one note. A note reading "Reviewed data. Called patient. 25 min." is insufficient, because it names no findings, no decision, and nothing tying the time to clinical work. A sufficient note records the date and minutes reviewed, the specific finding such as a worsening range-of-motion trend, the content of the patient call, the patient's response, and the clinical decision you made as a result. Write the note so a reviewer who never met the patient can see why the 25 minutes were spent and what they produced.

Why RTM Claims Get Denied: How to Prevent Each Failure

Most RTM denials trace back to the same handful of preventable errors, and each one has a specific fix you can build into your billing workflow before the claim ever leaves your office.

A missing therapy modifier blocks payment outright. When a PT, OT, or SLP furnishes RTM under a therapy plan of care, every claim needs a GP, GO, or GN modifier to identify the discipline. Build the modifier into your claim template so it attaches automatically by provider type, rather than relying on a biller to remember it on each claim.

Billing the wrong device code tier produces another reliable rejection. The musculoskeletal supply code 98977 and the lower-threshold 2026 code 98985 are mutually exclusive in the same 30-day period, so you bill one MSK device code, not both. Decide which tier applies based on whether your patient hit the 16-day threshold or the shorter 2-to-15-day window, then lock that choice for the period.

Stacking 98981 on the wrong base code is a coding error your system will repeat on every claim until you catch it. The add-on 98981 attaches only to 98980, never to the 2026 first-10-minute code 98979. If your patient's monitoring time reaches 20 minutes, bill 98980 and add 98981 for each additional 20-minute block. Route any management-code denial to a coder before you appeal, because appealing with an uncorrected code wastes the attempt.

Missing interactive communication strips the basis for treatment management billing. CMS requires at least one live phone or video contact with the patient or caregiver during the calendar month before you can bill 98980 or 98981. Schedule that call early in the month and log its date, so a thin or absent contact note never sinks an otherwise valid claim.

Concurrent RPM and RTM billing for the same patient in the same calendar month draws an automatic denial, because the two programs are mutually exclusive. Flag any patient enrolled in remote physiological monitoring before you open an RTM episode, and confirm no overlapping RPM claim exists for the month.

Expired orders and credentialing lapses block payment for reasons unrelated to your clinical work. An RTM service rendered after the plan of care expires, or under a clinician whose enrollment has lapsed, cannot be paid. Track each plan of care by start and expiration date, and set calendar reminders well ahead of credential renewal dates.

Timely filing violations are permanent. Medicare allows 12 months from the date of service, but many commercial payers demand submission within 90 to 180 days, and some windows run as short as 30 days. No appeal reverses a missed deadline. Keep a payer-specific filing calendar, and prioritize denied claims by remaining filing window rather than dollar amount.

The fix that outperforms all the rest is structural. Run a monthly denial trend report broken down by reason code, payer, and provider, then attack the highest-volume category first. Fifteen modifier denials from one payer in a month signal a workflow failure, not fifteen separate mistakes. Correcting the workflow once stops the pattern, while reworking claims one at a time only treats the symptom.

Building an RTM Program That Scales: Setup, Onboarding, and Workflow

A scalable RTM program starts with eligibility screening, because enrolling patients who don't meet medical necessity creates denials you can't fix after the fact. Screen each candidate against the qualifying condition your therapy plan of care will document, confirm the patient has had at least one prior visit with the ordering clinician, and verify they aren't already enrolled in RPM for the same month. Build this check into your intake so the wrong patients never reach enrollment.

Document consent before any monitoring begins, and treat that sequence as a hard gate rather than a step you complete later. A patient who logs data before written consent exists creates retroactive exposure that an auditor will find. Capture the patient's agreement to participate, the single-provider acknowledgment, the cost-sharing disclosure, and the right to revoke, then store all four with a date and the name of the person who obtained them. Written consent gives you far stronger audit protection than verbal, so make written the default.

Device assignment and patient education come next, and both need a record per patient. Log the date of assignment, the device type, the serial number, and confirmation that you educated the patient on how to use it. For PT and OT practices using a software application as the FDA-defined device, the same rule applies. The record proves the device existed and the patient knew how to operate it.

The 16-day data threshold is where most programs lose revenue, because a patient who falls short by even one day produces no billable device code for that 30-day period. Run mid-period checks around day 12 to 15 so you can intervene with a patient drifting below the threshold while there's still time to recover the days. Separately, schedule the interactive communication that CPT 98980 requires, since the calendar month for management codes and the 30-day episode for device codes don't align. A patient can clear the 16-day device threshold and still lose the management code because no phone or video contact happened that month.

Your billing workflow fails the moment it depends on someone manually counting transmission days across a spreadsheet. Time tracking demands actual minutes with date, duration, activity description, and the staff member's identity, and clinician review notes must be patient-specific rather than copy-forwarded from a prior encounter. A program that scales tracks all of this automatically and flags exceptions, so your billing team works denials by reason code instead of reconstructing logs at month-end.

Where Physitrack removes the administrative load

Physitrack automates the 16-day device engagement tracking that CMS requires for codes 98975 through 98981, monitoring usage patterns and flagging patients at risk of falling below the threshold before the claim period closes (Physitrack). Patients log exercises and symptoms through the PhysiApp mobile app while clinicians review compliance and outcome data in real time from the dashboard, and the platform generates audit-ready records for each submission. PhysiApp also carries the two-way secure messaging and video consultations that satisfy the interactive communication requirement for 98980 and 98981.

Physitrack integrates with more than 50 EMR and practice management systems, with bidirectional synchronization of patient demographics, prescription updates, and compliance tracking, and a native Epic integration that pushes RTM data into Epic's rehabilitation module (Physitrack). The platform holds ISO 27001 certification and HIPAA compliance for US deployments. For a clinic standing up RTM, that infrastructure replaces the manual log-keeping that produces most claim failures.

RTM Billing Codes at a Glance: Reference Table

The five core RTM codes split into two functions. Device supply codes (98975, 98976, 98977) cover setup and equipment over a 30-day episode of care. Treatment management codes (98980, 98981) cover clinician review time per calendar month.

Rates are 2025 national non-facility averages from the CMS Physician Fee Schedule and adjust by locality under GPCI. Confirm your region's rate before you submit.

Conclusion

RTM gives PT, OT, and SLP practices a reimbursement pathway that CMS has committed to through April 2030, and the codes stay on the New Technology List that long. Most claims fail not because the clinical work falls short, but because the documentation behind them does. The 16-day threshold, the interactive communication record, the therapy modifier, and the minute-by-minute time log all have to exist before a claim goes out.

Physitrack tracks the 16-day device engagement threshold automatically, generates audit-ready monitoring logs, and integrates with more than 50 EMR systems so your billing team works from clean records instead of manual spreadsheets. If your practice is ready to run RTM without the administrative drag that causes denials, request a walkthrough on the Physitrack RTM page and see how the documentation builds itself.

Frequently Asked Questions

Can PTAs and OTAs contribute to RTM billing time? Yes, physical therapy assistants and occupational therapy assistants can contribute monitoring time toward the treatment management codes 98980 and 98981, but only under the general supervision of a supervising PT or OT, with CQ or CO modifiers applied where required. The supervising clinician remains responsible for the plan of care and the billed claim. The assistant's time counts toward the 20-minute thresholds when the supervision and modifier rules are met.

Can RTM be billed during the same month as an in-person visit? Yes. RTM reimburses remote monitoring and treatment management, and nothing prevents you from also seeing the patient in clinic during the same period. The two services cover different work, so an in-person evaluation or treatment session and your RTM monitoring time are billed separately. Keep distinct documentation for each so an auditor can see that the RTM time was not duplicated in the in-person note.

What happens if two providers both submit RTM claims for the same patient? Only one clinician may bill RTM for a patient over a given 30-day period. When two providers submit claims for the same patient, the first claim received is reimbursed and every later claim is denied. Before you enroll a patient, confirm that no other practice is already running an RTM program for them, and document a single-provider acknowledgment as part of consent.

Does verbal consent satisfy CMS requirements? Verbal consent is permitted, but it gives you weaker audit protection than written consent. If you rely on verbal consent, record the date, the name of the person who obtained it, and a summary of what was disclosed, including cost-sharing and the patient's right to revoke. Written consent documented before monitoring begins is the safer standard, and you should refresh consent annually or whenever the program changes.

What is the difference between a 30-day episode of care and a calendar month for billing purposes? The device supply codes, including 98977, are billed per 30-day episode of care that starts when monitoring begins. The treatment management codes 98980 and 98981 are billed per calendar month that resets on the first of each month. These two windows rarely line up, so a single patient can have a device-code period that spans two calendar months. Track each window separately to avoid threshold and timing denials.