📋 RTM RequirementsTo bill RTM under CPT codes 98975, 98976, 98977, 98980, 98981, the following elements must be met:

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1) Patient Eligibility (CMS)

• Patient must have a condition where monitoring therapeutic data is medically necessary (e.g., COPD symptom tracking, inhaler use, musculoskeletal recovery, medication adherence).
• Device or software used must meet FDA definition of a medical device.

2) Initiating & Setup (AMA/CMS)

• 98975: Initial setup and patient education on use of RTM equipment/app.

“Remote therapeutic monitoring (e.g., musculoskeletal system, respiratory system), initial set‑up and patient education.” (AMA CPT® descriptor)

3) Supply Codes (AMA)

• 98976: Device supply, monitoring respiratory system status, per 30 days.
• 98977: Device supply, monitoring musculoskeletal system status, per 30 days.

“Supply of device(s)… each 30 days.” (AMA CPT® descriptor)

4) Treatment Management (CMS/AMA)

• 98980: First 20 minutes of treatment management per calendar month, including at least one interactive communication with patient/caregiver.
• +98981: Each additional 20 minutes.

“Treatment management services… requiring at least one interactive communication with the patient or caregiver during the calendar month.” (AMA CPT® descriptor)

5) Communication Requirement (AMA/CMS)

RTM treatment management codes 98980 and 98981 explicitly require at least one interactive communication with the patient or caregiver each month.

“Remote therapeutic monitoring treatment management services … requiring at least one interactive communication with the patient or caregiver during the calendar month.” (AMA CPT® Descriptor, adopted by CMS)

• What counts: two-way, real-time exchanges such as phone calls, video visits, or secure messaging with active back-and-forth.
• What does not count alone: one-way device data transmission, automated alerts, or sending educational materials without a reply.

6) Documentation (CMS)

• Document device/app type, condition monitored, patient education, treatment plan, time spent, and evidence of interactive communication.

7) Billing Restrictions (CMS)

• RTM cannot be double‑billed with RPM for the same patient/condition in the same month.
• Clinical staff time can be billed under general supervision when appropriate.

8) Frequency

• Device supply codes (98976/98977) are billed per 30 days.
• Treatment management codes (98980/98981) are billed monthly.

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