Economic Strategy

Monetizing the Deprescribe

RTM as Counter-Revenue When Better Clinical Care Means Fewer Fills

Economic strategy for independent pharmacy owners

Published: February 3, 2026

For Pharmacy Owners, Clinical Directors

Compliance note: This resource is educational and not legal advice. Medicare billing decisions must be made by the eligible billing practitioner and program compliance design should be reviewed by qualified counsel.

The Core Conflict

Clinical Reality

Deprescribing, tapering, and dose optimization are high-value clinical work that reduces falls, cognitive impairment, and withdrawal syndromes.

Economic Reality

The dispensing model monetizes product movement. If the medication stops, the refill stops.

The Solution

Remote Therapeutic Monitoring (RTM) pays for structured management and monitoring work during active titration or tapering.

Executive Summary

Pharmacists are trained to reduce polypharmacy and improve medication safety, but the traditional dispensing model is volume-dependent. When a pharmacist successfully tapers or discontinues a high-risk medication, the patient is safer, but the pharmacy may lose ongoing prescription volume and per-fill gross margin. In parallel, pharmacy contracting economics can include performance adjustments and pharmacy price concessions that interact with adherence and utilization patterns, so the financial picture is not always intuitive. (CMS)

Remote Therapeutic Monitoring (RTM) is a Medicare Part B payment pathway that can help align incentives by paying for ongoing therapeutic monitoring and treatment management work during active titration or tapering. The RTM code family includes an initial set-up and education code (98975), device supply codes (98976, 98977, and additional codes beginning in 2026), and treatment management codes (98980, 98981, and an additional code beginning in 2026). Importantly, RTM is billed by physicians and non-physician practitioners (NPPs) eligible to provide evaluation and management services, not by pharmacies directly. Pharmacies typically participate through a contracted clinical services model in which the billing practitioner submits the claim and the pharmacy is paid under an agreement for defined operational work. (CMS)

This guide shows how to structure a deprescribing program so that the clinical work is real, measurable, and supportable under RTM rules, while avoiding the most common audit failures: missing required elements, time misallocation, double counting, and documentation that reads like dispensing logistics.

Section index

I. The Misalignment: “Paid to Fill”
II. RTM in Medicare: What It Is and What It Is Not
III. The Economic Model: Replace Product Margin With Service Margin
IV. The Clinical Use Case: Benzodiazepine Taper as RTM
V. Operational Guardrails That Prevent Audit Failure
VI. Contracting Model: How Pharmacies Get Paid
VII. Implementation Blueprint: 30-Day Build, 60-Day Scale
References

I. The Misalignment: “Paid to Fill”

The core economic problem is straightforward.

Clinical reality

A meaningful fraction of avoidable harm in older adults is medication-related: falls, delirium, cognitive impairment, sedation, respiratory depression, and withdrawal syndromes. Deprescribing, tapering, and dose optimization are high-value clinical work.

Economic reality

The dispensing model monetizes product movement. If the medication stops, the refill stops. If the pharmacist’s best clinical intervention reduces medication volume, the near-term business outcome can be less prescription revenue.

Operational consequence

If you want to scale deprescribing safely, you need a reimbursement mechanism that pays for structured management and monitoring work, not the product.

II. RTM in Medicare: What It Is and What It Is Not

RTM is often described in loose marketing terms. The policy details matter.

RTM is a defined CPT code family with specific elements

CMS recognizes RTM as a set of services that include:

Initial set-up and patient education on equipment (98975)
Device supply and data transmission support for monitoring therapeutic status (98976, 98977, and additional codes beginning in 2026)
Treatment management time in a calendar month with required interactive communication (98980 and 98981, and an additional code beginning in 2026) (CMS)

RTM is billed by eligible practitioners, not pharmacies

CMS states that only physicians and non-physician practitioners eligible to provide evaluation and management services can bill remote monitoring services. Pharmacies should design RTM programs assuming the billing practitioner submits the Part B claim and the pharmacy participates through a contracted services relationship. (CMS)

Treatment management codes have an interactive communication requirement

CMS’s published long descriptors for RTM treatment management (98980 and 98981) include a requirement for at least one interactive communication with the patient or caregiver during the calendar month, and the time is attributed to the physician or other qualified health care professional as specified by the descriptor. Practically, this means you must engineer the workflow so that the billing practitioner has a real patient interaction and can document time and decisions. (CMS)

RTM device supply codes are day-quantized, and the rules changed in 2026

CMS’s therapy code list updates indicate that RTM device supply codes are structured by days in a 30-day period. Beginning in 2026, the respiratory and musculoskeletal RTM device supply codes distinguish 16 to 30 days from 2 to 15 days (via new codes). If you are modeling program economics, you need to design data collection so you actually qualify for the device supply code you expect.

RTM and RPM cannot be billed together

CMS states you cannot bill remote physiologic monitoring and RTM together for the same patient in the same 30-day period. Do not design a hybrid that assumes you can stack both families in the same month. (CMS)

Only one practitioner can bill remote monitoring per patient per 30-day period

CMS states only one practitioner can bill for remote monitoring per patient in a 30-day period. Your contracting and attribution model must account for this, especially in multi-specialty environments. (CMS)

RTM does not require an established patient relationship (RPM does)

CMS notes that remote physiologic monitoring, but not RTM, requires an established patient relationship. This matters for acquisition and onboarding workflows, but it does not remove the need for medical necessity and defensible documentation. (CMS)

III. The Economic Model: Replace Product Margin With Service Margin

If you want a credible business case, do not anchor on generic dollar figures. Build a model that is structurally correct, then plug in your locality’s allowed amounts.

A. Revenue components (structural)

During an active taper or titration month, an RTM program may include:

One-time onboarding
• RTM initial set-up and patient education (98975) (CMS)
Monthly device supply (if applicable and qualified)
• RTM device supply codes, which are tied to days-in-use thresholds in a 30-day period
Monthly treatment management
• RTM treatment management codes that require interactive communication and qualified professional time (CMS)

B. How the money actually flows in a pharmacy-led model

Medicare pays the eligible billing practitioner. The pharmacy is typically compensated via contract for defined services that support care delivery (for example, outreach, survey administration, adherence tracking, and escalation support). Because the billing practitioner must meet the code requirements, the contract should specify what the pharmacy does versus what the practitioner does, and how documentation responsibilities are split. (CMS)

C. Practical modeling steps

Pull your locality rates from CMS PFS sources for the relevant year. Do not use blog tables as authoritative rates.
Decide whether your program qualifies for RTM device supply codes based on days-in-use thresholds.
Decide the operational cadence that produces at least one real interactive communication in the month and supports qualified professional time for treatment management. (CMS)

IV. The Clinical Use Case: Benzodiazepine Taper as RTM

A taper program is ideal for RTM because it is time-bounded, clinically sensitive, and benefits from continuous monitoring.

Clinical goal

Reduce benzodiazepine exposure safely while monitoring for withdrawal symptoms, rebound anxiety, insomnia, tremors, and functional decline.

RTM framing

You are not billing “for stopping the medication.” You are billing for structured monitoring and treatment management while a clinician-directed taper plan is executed.

A. Build a “Taper Care Plan” with explicit monitoring targets

Baseline (week 0)
• Confirm indication and risk profile (falls risk, cognitive effects, respiratory risk, co-prescribed opioids)
• Define taper schedule and contingency rules (hold, slow, or pause taper based on symptoms)
• Define what data will be collected and how often (symptom scoring, adherence confirmation, side effect flags)
Monitoring phase (weeks 1 to N)
• Patient reports symptom and adherence data at a defined cadence
• Program triggers escalation when thresholds are exceeded
• Billing practitioner performs at least one real interactive communication in the month and documents decisions and time that meet RTM treatment management requirements (CMS)

B. Data elements that actually support the RTM narrative

Symptom response data (therapy response)
• Anxiety severity rating, sleep quality, tremor severity, daytime sedation, cognitive complaints
Adherence data (therapy adherence)
• Confirmation of reduced dosing schedule adherence, missed doses, early refill attempts
Decision and action data
• Taper continued, taper held, taper slowed, referral recommended, urgent evaluation advised

This is the difference between “we watched a dashboard” and “we managed therapy.”

C. Medical necessity framing that is defensible

Do not write “CMS requires RTM to monitor a specific condition” as a blanket rule. Write what is supportable: monitoring must be medically reasonable and necessary and tied to a treatment plan and clinical decisions. In a taper program, the underlying clinical rationale is monitoring response and safety during a clinician-directed medication change. (CMS)

V. Operational Guardrails That Prevent Audit Failure

Most programs fail on avoidable mechanics. These are the guardrails to implement.

Avoid double counting and contamination with dispensing work: If the documentation reads like refill logistics or dispensing counseling, you are inviting reclassification risk. Keep taper management work in a clinical record context with explicit clinical intent, and keep dispensing tasks separate.
Design for the interactive communication requirement: Because RTM treatment management requires at least one interactive communication in the month, your workflow must plan for a real patient or caregiver touchpoint by the billing practitioner. Do not rely on asynchronous messaging alone unless you have a defensible policy interpretation and documentation framework. (CMS)
Attribute time correctly: The RTM treatment management descriptors specify physician or other qualified health care professional time. The safe operational model is: pharmacy staff gathers data and triages, then the billing practitioner performs the clinical decision-making communication and documents the time. (CMS)
Respect the one-practitioner-per-30-day rule: You need a single billing practitioner attribution for remote monitoring per patient per 30-day period. Do not allow multiple clinicians to unknowingly bill overlapping remote monitoring on the same patient panel. (CMS)
Do not bill RPM and RTM together: If the patient is on RPM for a physiologic condition and you want RTM for a taper program, you must choose which remote monitoring family is billed in that 30-day period or re-sequence the programs. (CMS)
Track days-in-use when device supply codes are in scope: RTM device supply codes are structured around days-in-use thresholds. Your operational design needs a reliable way to track and demonstrate qualification if you are billing those codes.
Consent and program enrollment artifacts: CMS explicitly states consent requirements for RPM; many compliance programs extend the same discipline to RTM implementations as a best practice because both are non-face-to-face remote monitoring services. At minimum, capture and retain consent and start dates as audit artifacts. (CMS)

VI. Contracting Model: How Pharmacies Get Paid Without Creating Compliance Risk

Because the physician or eligible NPP bills Medicare, pharmacies typically monetize RTM-enabled deprescribing by contracting with the billing practice.

A. Typical structure

Billing practitioner bills RTM codes when requirements are met
Pharmacy is paid under an agreement for defined operational services (care coordination support, data collection support, outreach, documentation assistance, escalation workflows)

B. Practical guardrails (high-level)

Avoid compensation tied to volume of referrals
Use fair market value and commercial reasonableness principles
Define responsibilities so that required elements (interactive communication, qualified time, medical decision documentation) are clearly owned by the billing practitioner

This is not a substitute for legal review. It is the minimal posture that reduces predictable compliance exposure.

VII. Implementation Blueprint: 30-Day Build, 60-Day Scale

Days 1 to 10: Program definition
- Choose the clinical pathway (benzodiazepine taper, opioid taper, gabapentinoid reduction, high-risk anticholinergic reduction)
- Define thresholds, escalation logic, and monitoring cadence
- Define documentation templates and the monthly interactive communication plan (CMS)
Days 11 to 30: Partner and workflow integration
- Confirm billing practitioner attribution and one-practitioner rule handling (CMS)
- Implement consent capture and enrollment tracking
- Stand up survey or data collection mechanism and day qualification tracking if billing device supply codes
- Pilot with a small cohort (10 to 30 patients) and refine artifacts until they are review-ready
Days 31 to 60: Scale operations
- Standardize taper templates into repeatable playbooks
- Build a monthly audit packet output: enrollment, consent, data summary, interactive communication note, treatment decision trail, and time documentation for the billing practitioner (CMS)
- Expand to additional taper pathways and prescriber partners

FairPath note

FairPath is FairPath’s clinical operations platform for pharmacy-led programs. If you use FairPath or any other platform, the core requirement is the same: your RTM deprescribing workflow must produce patient-level artifacts that support the RTM elements described above, and it must preserve clean separation from dispensing documentation.

Conclusion: Aligning Ethics and Economics

RTM can realign the financial incentives around deprescribing by paying for structured monitoring and treatment management during taper and titration protocols. The winning implementation is not a marketing claim about recurring revenue. It is an operational system that reliably produces the required monthly elements, maintains correct billing attribution, avoids double counting, and creates documentation that reads like medical management rather than dispensing logistics. (CMS)

References

CMS Medicare Learning Network (MLN901705). Telehealth and Remote Monitoring. December 2025. (CMS)
CMS MLN Matters (MM12446) and related transmittal R11118CP. 2022 Annual Update to the Therapy Code List. November 2021. (CMS)
CMS MLN Matters (MM14250) and related transmittal R13431CP. Therapy Code List 2026 Annual Update. November 2025. (CMS)
U.S. Department of Health and Human Services Telehealth. Billing for remote patient monitoring. January 2025 update. (telehealth.hhs.gov)

FairPath is designed to handle this complexity for you.

While most platforms simply record what happened, FairPath actively runs the program. It continuously monitors every patient, staff action, and billing rule across CCM, RPM, RTM, and APCM, intervening immediately when a requirement is missed.

This allows you to scale your own program without losing quality, breaking trust with physicians, or losing control of your revenue. We provide the precision of an automated medical director without the chaos.

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