RTM Billing Guide: Remote Therapeutic Monitoring CPT Codes & Requirements

Understanding RTM Billing: A Newer Opportunity

Remote Therapeutic Monitoring is one of Medicare's newer remote monitoring programs, introduced to extend the benefits of remote care beyond the physiologic data collected by RPM. While RPM focuses on vital signs from FDA-cleared devices, RTM covers therapy-related data — pain scores, medication adherence, exercise completion, respiratory function, and other non-physiologic measures that are central to managing musculoskeletal and respiratory conditions.

For practices in orthopedics, pulmonology, physical medicine, and primary care, RTM opens a billing pathway for monitoring therapy outcomes between visits — work that has historically been performed without reimbursement.

This guide covers all five RTM CPT codes, the critical differences from RPM, qualifying conditions, and practical strategies for building an RTM billing program.

RTM vs RPM: The Fundamental Distinction

The most important thing to understand about RTM is what makes it different from RPM:

• RPM collects physiologic data generated automatically by FDA-cleared devices (blood pressure cuffs, scales, glucometers, pulse oximeters)
• RTM collects non-physiologic, therapy-related data that can include patient self-reports (pain scores, symptom diaries, therapy adherence, functional assessments)

This distinction has significant practical implications. RTM programs can use digital health applications, patient-facing apps, and simpler data collection tools — they are not limited to FDA-cleared monitoring devices. This makes RTM more accessible for practices that do not already have device-based monitoring infrastructure.

The Five RTM CPT Codes: A Detailed Breakdown

RTM billing uses five CPT codes organized into two categories: device supply/data collection (98975, 98976, 98977) and treatment management services (98980, 98981).

CPT 98975: Initial Setup and Patient Education

Estimated Reimbursement: ~$19 (one-time per treatment episode)

What it covers: The initial setup of the RTM monitoring system, including configuring the data collection tool, educating the patient on how to report data, and establishing the monitoring protocol.

Key requirements:

• Billed once per patient per treatment episode
• Must include patient education on data reporting methods
• The ordering provider must have an established patient-provider relationship
• The monitoring protocol should be documented in the care plan

Billing notes: Similar to RPM's 99453, this is a one-time setup code. While the reimbursement is modest, it establishes the patient in the RTM program and initiates the data collection period. Practices should not overlook this code when enrolling new RTM patients.

CPT 98976: Device Supply — Respiratory System

Estimated Reimbursement: ~$50 per month

What it covers: The supply and monitoring of a device (or digital tool) for respiratory system monitoring, including data recording and transmission over a 30-day period.

Key requirements:

• Patient must have a qualifying respiratory condition (COPD, asthma, post-COVID recovery, etc.)
• Minimum of 16 days of data recording within the 30-day billing period
• Data must be collected through a monitoring device or digital platform
• The data can include self-reported respiratory symptoms, medication adherence, peak flow readings, or therapy completion

Billing notes: CPT 98976 is the respiratory-specific device supply code. The 16-day data requirement mirrors RPM's threshold for 99454. The key advantage is that the "device" can be a digital health platform or app — it does not need to be a traditional FDA-cleared medical device. This significantly lowers the barrier to entry for respiratory RTM programs.

CPT 98977: Device Supply — Musculoskeletal System

Estimated Reimbursement: ~$50 per month

What it covers: The supply and monitoring of a device (or digital tool) for musculoskeletal system monitoring, including data recording and transmission over a 30-day period.

Key requirements:

• Patient must have a qualifying musculoskeletal condition (post-surgical recovery, chronic pain, orthopedic rehabilitation, etc.)
• Minimum of 16 days of data recording within the 30-day billing period
• Data can include self-reported pain levels, range of motion measurements, exercise adherence, and functional outcome scores
• The monitoring tool can be a digital platform, app, or connected device

Billing notes: CPT 98977 serves the same function as 98976 but for musculoskeletal conditions. This code is particularly relevant for orthopedic practices monitoring post-surgical recovery (total knee replacement, total hip replacement, rotator cuff repair) and physical medicine practices tracking therapy adherence and outcomes.

CPT 98980: Treatment Management — First 20 Minutes

Estimated Reimbursement: ~$48 per month

What it covers: The first 20 minutes of clinical staff time spent reviewing RTM data, managing the patient's treatment plan, and communicating with the patient about therapy progress.

Key requirements:

• Minimum of 20 minutes of clinical staff time per calendar month
• Clinical staff can perform the work under general supervision of the billing provider
• Time must be documented with date, duration, and activities performed
• Activities include data review, treatment plan updates, patient communication, and care coordination

Billing notes: CPT 98980 covers the treatment management component of RTM — the clinical time spent reviewing therapy-related data and acting on it. Unlike RPM's 99457, there is no explicit requirement for interactive patient contact, though communication with the patient about their therapy progress is a standard practice component.

CPT 98981: Treatment Management — Additional 20 Minutes

Estimated Reimbursement: ~$38 per month

What it covers: Each additional 20 minutes of clinical staff time beyond the first 20 minutes covered by 98980.

Key requirements:

• Can only be billed after 98980 has been satisfied
• Same documentation requirements as 98980
• Additional 20-minute increments

Billing notes: As with RPM's 99458, this additional time code is frequently underutilized. For complex patients in active rehabilitation or with challenging pain management protocols, clinical staff may easily exceed 20 minutes per month in data review and treatment management.

Qualifying Conditions for RTM

Respiratory Conditions (98976)

RTM for respiratory monitoring is relevant for patients with:

• COPD — Monitoring respiratory therapy adherence, inhaler usage, symptom patterns, and exacerbation frequency
• Asthma — Tracking medication adherence, peak flow variability, trigger identification, and action plan compliance
• Post-COVID respiratory recovery — Monitoring respiratory rehabilitation progress, dyspnea levels, and functional recovery
• Pulmonary rehabilitation — Tracking exercise completion, oxygen saturation trends (when combined with self-reported data), and therapy adherence
• Other chronic respiratory conditions — Any condition with an active therapeutic component amenable to remote monitoring

Musculoskeletal Conditions (98977)

RTM for musculoskeletal monitoring is relevant for patients with:

• Total knee replacement recovery — Monitoring post-operative range of motion, pain levels, physical therapy adherence, and functional milestones
• Total hip replacement recovery — Tracking rehabilitation progress, weight-bearing status, and functional outcomes
• Chronic pain syndromes — Monitoring pain scores, medication adherence, functional impact, and therapy engagement
• Rotator cuff repair — Tracking rehabilitation exercise completion, pain trends, and range of motion progress
• Physical therapy adherence — Monitoring home exercise program completion for any orthopedic condition
• Chronic musculoskeletal conditions — Osteoarthritis, chronic low back pain, fibromyalgia, and other conditions with active therapeutic monitoring needs

Revenue Projections and Financial Modeling

Per-Patient Monthly Revenue

When RTM codes are billed appropriately, the estimated per-patient monthly revenue breaks down as follows:

CPT Code	Estimated Rate	Frequency
98975	~$19	One-time (setup)
98976 or 98977	~$50	Monthly
98980	~$48	Monthly
98981	~$38	Monthly (when time threshold met)

Estimated recurring monthly revenue per patient: ~$98–$136

The range depends on whether 98981 is consistently billed. The device supply code (98976 or 98977) is condition-specific — a patient with a respiratory condition uses 98976, while a musculoskeletal patient uses 98977.

Note: All reimbursement amounts are estimates based on CMS published fee schedules. Actual rates vary by geographic region, MAC jurisdiction, and payer contracts.

Practice-Level Revenue Modeling

Active RTM Patients	Estimated Monthly Revenue	Estimated Annual Revenue
25	~$2,500	~$30,000
50	~$5,000	~$60,000
100	~$10,000	~$120,000
200	~$20,000	~$240,000

These figures assume an average of ~$100 per patient per month in recurring codes. RTM programs can have lower overhead than RPM because they may not require specialized medical devices — digital health platforms and patient-facing apps can serve as the data collection tool.

RTM vs RPM: Side-by-Side Comparison

Dimension	RTM	RPM
Data Type	Non-physiologic, therapy-related	Physiologic vital signs
Self-Reported Data	Allowed	Not allowed
Device Requirement	Digital tool or device	FDA-cleared medical device
Minimum Data Days	16 of 30 days	16 of 30 days
Setup Code	98975 (~$19)	99453 (~$19)
Device Supply Code	98976/98977 (~$50/mo)	99454 (~$55/mo)
Clinical Review Code	98980 (~$48/mo)	99457 (~$48/mo)
Additional Time Code	98981 (~$38/mo)	99458 (~$38/mo)
Typical Conditions	COPD rehab, post-surgical, chronic pain	Hypertension, diabetes, heart failure
Concurrent Billing	Can bill with RPM for different conditions	Can bill with RTM for different conditions

Common RTM Billing Mistakes

Mistake 1: Confusing RTM and RPM Data Types

The most common compliance error is billing RTM for physiologic data that should be billed under RPM, or vice versa. Blood pressure readings from a device are RPM (99454). Pain scores from a patient app are RTM (98977/98980).

Solution: Clearly define which data streams feed each program at the time of enrollment. Document the RTM data type (self-reported pain, therapy adherence, etc.) separately from any RPM physiologic data.

Mistake 2: Not Meeting the 16-Day Data Threshold

Like RPM, RTM requires 16 days of data collection within the 30-day billing period. Practices that do not actively monitor patient reporting compliance will miss this threshold.

Solution: Use digital platforms with automated reminders that prompt patients to report data daily. Track reporting compliance dashboards and conduct outreach to patients falling behind the threshold.

Mistake 3: Using the Wrong Device Supply Code

Billing 98976 (respiratory) for a musculoskeletal patient, or 98977 (musculoskeletal) for a respiratory patient, results in claim denials.

Solution: Match the device supply code to the patient's primary monitored condition. If a patient has both respiratory and musculoskeletal conditions, determine which condition's therapy is being actively monitored through the RTM program.

Mistake 4: Inadequate Treatment Management Documentation

As with RPM clinical review codes, RTM treatment management time (98980/98981) must be documented with date, duration, and description of activities.

Solution: Use structured time-logging templates. A compliant entry might read: "Reviewed 3 weeks of post-TKR pain scores and PT exercise logs. Patient reporting improving range of motion but persistent nocturnal pain. Discussed with care team; recommended adjustment to evening pain management protocol. 25 minutes."

Getting Started: Building an RTM Program

Step 1: Identify Your Target Population

Review your patient panel for conditions amenable to therapeutic monitoring. Orthopedic practices should look at post-surgical patients. Pulmonology practices should target COPD and asthma patients with active therapy plans. Primary care practices can identify chronic pain patients with ongoing therapeutic management.

Step 2: Select a Data Collection Platform

Choose a digital health tool that supports patient self-reporting, meets the 16-day data collection requirement, and integrates with your documentation workflow. The platform should make it easy for patients to report pain scores, therapy adherence, symptom diaries, or functional outcomes.

Step 3: Establish Clinical Protocols

Define which data points will be collected for each condition, how frequently patients should report, and what clinical response is triggered by specific data patterns (e.g., worsening pain trends, declining therapy adherence).

Step 4: Train Staff on RTM-Specific Requirements

Ensure clinical and billing staff understand the differences between RTM and RPM, the correct device supply code mapping (98976 vs 98977), and the treatment management documentation requirements.

Step 5: Monitor and Optimize

Track billing rates by CPT code monthly. If device supply codes (98976/98977) are being denied, investigate the 16-day data threshold. If 98981 is rarely billed, review time logs for patients where clinical staff exceeded 20 minutes.

Conclusion

RTM billing extends the remote monitoring reimbursement framework to conditions and data types that RPM cannot cover. For orthopedic practices managing post-surgical recovery, pulmonology practices monitoring respiratory therapy, and primary care practices tracking chronic pain management, RTM provides a direct revenue pathway for the therapy monitoring work these practices already perform.

The financial opportunity — an estimated ~$100+ per patient per month in recurring revenue — is meaningful, particularly when combined with the lower implementation costs that come from using digital health platforms rather than specialized medical devices. And for practices already billing RPM, adding RTM for patients with qualifying musculoskeletal or respiratory conditions creates additional per-patient revenue without cannibalizing existing programs.

As with all chronic care billing programs, the key to success is disciplined documentation, systematic data collection, and consistent time tracking. Practices that build these operational foundations will capture revenue that would otherwise go unbilled.

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Disclaimer: This article is for informational purposes only and does not constitute medical, legal, or billing advice. CPT code reimbursement amounts are estimates based on CMS published fee schedules and may vary by region, payer, and clinical circumstances. State-specific regulatory information is subject to change. Always consult qualified healthcare and billing professionals for guidance specific to your practice.