A patient recovering from rotator cuff surgery is sent home with a home exercise program, a follow-up appointment in six weeks, and not much else in between. If the exercises hurt too much and the patient quietly stops doing them, nobody finds out until the next visit — by which point six weeks of progress has been lost. Remote therapeutic monitoring (RTM) exists to close that gap: it gives physical therapists, occupational therapists, and other qualified providers a Medicare-recognized way to track whether a patient is actually doing the prescribed therapy, how the musculoskeletal or respiratory system is responding, and whether the care plan needs to change before the next in-person visit.

RTM is a relatively new addition to the Current Procedural Terminology (CPT) code set, and it is frequently confused with remote patient monitoring (RPM), a more established and separately billed category. The two programs sound alike, share a similar structure, and are often built on similar technology platforms — but they cover different kinds of data, different eligible billers, and different billing codes. This article walks through what RTM covers, how its CPT codes work, who can bill for it, and the workflow considerations that come up when a practice sets up an RTM program. Codes, payment amounts, and supervision rules are revised through the Centers for Medicare & Medicaid Services (CMS) annual Medicare Physician Fee Schedule (PFS) rulemaking, so program leaders should always confirm current-year specifics against CMS guidance before finalizing a billing workflow.

What Is Remote Therapeutic Monitoring?

Remote therapeutic monitoring is a category of CPT codes, established by the American Medical Association (AMA) and recognized for Medicare payment by CMS, that covers the collection and clinical review of non-physiologic patient data related to musculoskeletal status, respiratory status, and adherence or response to a therapy plan. Data can come from a connected device — a wearable sensor tracking range of motion, for example, or a spirometer — or it can be patient-reported through a digital application, such as a daily pain scale or an exercise-completion log.

That patient-reported piece is one of the features that most distinguishes RTM from earlier remote monitoring categories: RTM was designed from the outset to accommodate self-reported outcomes data alongside device-generated data, which is why it fits naturally into physical therapy, occupational therapy, and behavioral health programs where adherence and subjective symptom response are central to the clinical picture.

How Does RTM Differ from RPM?

Remote patient monitoring (RPM), billed under a separate code family, is built around physiologic data — blood pressure, weight, blood glucose, pulse oximetry — captured automatically by an FDA-registered medical device and transmitted without the patient needing to manually enter anything. RTM, by contrast, is explicitly built to include non-physiologic data, and it allows for patient self-reporting rather than requiring only automated device transmission.

The practical differences that matter most for program design:

  • Data type. RPM = physiologic vital signs. RTM = musculoskeletal system status, respiratory system status, therapy adherence, and therapy response — data that is often subjective or functional rather than a vital sign.
  • Who can bill. RPM has historically been restricted to physicians and certain non-physician practitioners. RTM was designed to also be billable by physical therapists, occupational therapists, and speech-language pathologists, who generally cannot bill RPM codes under Medicare’s evaluation-and-management framework.
  • Patient relationship. CMS guidance has distinguished RPM and RTM on whether an established patient relationship is required; practices should confirm the current requirement for each code family before enrolling patients, since this is exactly the kind of detail that shifts between rulemaking cycles.
  • No double-billing the same month. CMS has been clear that RPM and RTM generally cannot both be billed for the same patient by the same practice in the same calendar month, since they are not intended to stack for the same monitoring episode.

Because the two categories overlap in concept — both involve a device or app, a monitoring window, and clinical staff time — practices sometimes mistakenly bill the wrong family for the clinical scenario. The deciding question is usually simple: is the data physiologic (RPM) or is it musculoskeletal/respiratory status, therapy adherence, or therapy response (RTM)?

What Are the RTM CPT Codes?

The RTM code family, as established by the AMA and adopted into the Medicare Physician Fee Schedule, separates device setup and data-supply codes from clinical treatment-management codes, mirroring the structure used for RPM.

CPT 98975 — Initial Set-Up and Patient Education

Billed once per episode of care, this code covers the initial setup of the RTM device or application and patient (or caregiver) education on how to use it. Under CMS guidance, this code is generally reportable only after at least 16 days of data have actually been collected, which ties the setup fee to demonstrated patient engagement rather than simply handing someone a device.

CPT 98976 and 98977 — Device Supply (Respiratory and Musculoskeletal)

These two codes cover the medical device itself and the transmission of scheduled recordings or programmed alerts over a 30-day period — 98976 for monitoring the respiratory system, 98977 for monitoring the musculoskeletal system. As with the RPM device-supply code, CMS guidance has generally required at least 16 days of data collection within the 30-day period before the code can be billed, sometimes called the “16-day rule.” A single missed week from illness, travel, or disengagement can be enough to knock an entire month’s device-supply billing out of eligibility, which is a common point of confusion for new programs.

CPT 98978 — Cognitive Behavioral Therapy Monitoring Device

A newer addition to the RTM family, this code covers device supply specific to monitoring therapy adherence and response in a cognitive behavioral therapy context, extending the RTM structure beyond strictly musculoskeletal and respiratory use cases into behavioral health monitoring.

CPT 98980 and 98981 — Treatment Management

98980 covers the first 20 minutes, per calendar month, of treatment management services furnished by a physician or other qualified health care professional, and requires at least one interactive communication with the patient or caregiver during that month. 98981 is the add-on code for each additional 20-minute increment in the same calendar month. “Interactive communication,” per CMS guidance, generally means real-time, synchronous, two-way interaction — a phone or video check-in — not an asynchronous text message or portal message, since those do not meet the real-time standard.

Note that CPT descriptions and code numbers above reflect the code set as generally described in CMS and AMA guidance around 2024; CMS has continued to refine RTM billing policy in subsequent rulemaking cycles, including additional codes and supervision changes, so the current-year Medicare Physician Fee Schedule and its associated transmittals remain the authoritative reference for any billing decision.

What Data Qualifies for RTM?

RTM data generally falls into four categories, all tied to the descriptor language used across the 98975–98981 code family:

  • Musculoskeletal system status — range of motion, pain levels, functional mobility, or other data relevant to an orthopedic or physical therapy plan of care.
  • Respiratory system status — symptom tracking, device-based readings, or patient-reported respiratory function relevant to a pulmonary rehabilitation or respiratory therapy plan.
  • Therapy adherence — whether the patient is actually completing prescribed exercises, using a prescribed device, or following a therapy protocol as directed.
  • Therapy response — how the patient’s condition or symptoms are responding to the therapy being delivered, which may be captured through patient-reported outcome measures.

A key structural feature of RTM is that this data does not have to come exclusively from an automated device transmission. Patient-reported entries — logging into an app to record a pain score or confirm a completed home-exercise session — can satisfy RTM’s data-collection requirement in a way that would not satisfy RPM’s requirement for automated physiologic device data. This is central to why RTM fits physical therapy and behavioral health workflows so well: much of what a therapist needs to know (did the patient do the exercises, how much did it hurt, is function improving) is inherently self-reported rather than something a sensor captures automatically.

Who Can Bill RTM Services?

One of the most significant practical differences between RTM and RPM is the list of eligible billing practitioners. RTM codes were structured so that physical therapists, occupational therapists, and speech-language pathologists — practitioners who typically cannot independently bill RPM’s evaluation-and-management-based codes — can order and bill RTM services directly, without requiring a physician or nurse practitioner to bill on their behalf.

Physicians and other qualified health care professionals, including nurse practitioners and physician assistants, can also bill RTM when it fits within their scope of practice and the plan of care. Supervision requirements for clinical staff involved in furnishing RTM — including therapy assistants — have been addressed in CMS rulemaking and have shifted over successive years (for example, moving certain supervision requirements from direct to general supervision in some settings), so practices should verify current supervision rules for their specific practitioner types and setting before building staffing models around RTM.

Program and Workflow Considerations

Setting up an RTM program involves more than selecting a device or app. Considerations that commonly come up in practice include:

  • Choosing the right monitoring modality for the plan of care. A musculoskeletal rehab program monitoring exercise adherence is a different clinical and technical build than a respiratory program tracking symptom flares, even though both bill from the same overall code family.
  • Meeting the 16-day data threshold without over-relying on automation. Because RTM explicitly allows patient self-report, programs need a workflow — reminders, app prompts, care coordinator check-ins — that keeps patients actually logging data, since a device sitting unused doesn’t generate billable days.
  • Tracking interactive communication separately from data review. Treatment management codes require documented, real-time interactive communication; a clinician passively reviewing a dashboard without patient contact does not satisfy that requirement, so workflows need to capture and timestamp actual calls or video visits distinctly from data-review time.
  • Avoiding overlap with RPM and other care-management codes. Practices running multiple remote-monitoring or care-management programs need billing workflows that prevent the same clinical minutes from being counted toward more than one code family in the same month.
  • Documentation supporting medical necessity. As with any Medicare-billed service, the plan of care, the clinical rationale for monitoring, and the specific minutes and communications furnished each month should be documented in a way that would hold up under an audit.

Frequently Asked Questions

Can a physical therapist bill RTM without a physician’s involvement?

Generally, yes. RTM was structured so that physical therapists, occupational therapists, and speech-language pathologists can independently order and bill RTM codes as part of their plan of care, unlike RPM, which has historically required physician or qualifying non-physician practitioner billing. Confirm current scope-of-practice and state rules before implementing.

Does RTM require an established patient relationship?

CMS guidance has drawn a distinction between RPM and RTM on this point, and the details have evolved across rulemaking cycles. Practices should not assume RTM and RPM share identical relationship requirements and should verify the current-year CMS Physician Fee Schedule guidance before enrolling new patients.

Can a practice bill RPM and RTM for the same patient in the same month?

Generally no — CMS guidance indicates these code families are not intended to be billed together for the same patient by the same practice in the same calendar month, since both represent monitoring and management of the patient’s condition. Patients can potentially transition between programs as clinical needs change.

What counts as “interactive communication” for RTM treatment management codes?

CMS guidance describes interactive communication as real-time, synchronous, two-way interaction, such as a live phone or video call — not asynchronous methods like text messages, emails, or portal messages, which do not meet the real-time standard required to bill the treatment management codes.

Is this article medical or billing advice?

No. This overview describes RTM at a general, non-exhaustive level as of 2024 for informational purposes only. CPT codes, payment rates, supervision requirements, and coverage policy are updated annually by CMS and interpreted through AMA CPT guidance; any organization implementing or billing RTM should consult the current CMS Physician Fee Schedule, official CPT resources, and qualified billing/compliance counsel rather than relying on this article alone.