Remote Therapeutic Monitoring, Done Right.

Yes. RTM is “sometimes therapy.” Physical Therapists, Occupational Therapists, and Speech-Language Pathologists can bill RTM within their scope when it is delivered under a therapy plan of care. Physicians and other qualified health care professionals can also bill RTM. Use GP/GO/GN modifiers when RTM is provided as therapy under a plan of care, and follow your MAC’s supervision and documentation rules for the setting.

RTM requires that data be captured and transmitted by a medical device as defined by the FDA. That can include software as a medical device (SaMD), such as a qualified RTM app, but generic wellness apps or informal text messages are not sufficient. You can use SMS or voice to nudge patients, but the data of record must be entered into, or generated by, an RTM-eligible device or app that your billing team can name and document.

For 2025 device-supply codes 98976/98977 (and 98978 where covered), you generally need at least 16 days of RTM data in a 30-day period to bill. Management codes 98980/98981 do not have a 16-day requirement, but you still need legitimate RTM data and documented interaction.

Beginning in 2026, new codes 98984/98985/98986 allow you to bill for 2–15 days of monitoring, while 98976/98977/98978 are updated to explicitly cover 16–30 days.

You must have at least one synchronous, real-time conversation (audio-only telephone or audio-video). Crucial Update: Automated nudges, text messages, AI chat, or portal messages do not count toward the interactive requirement or the clinical labor time.

No. Only one practitioner can bill RTM (or RPM) services for a patient in a given 30-day period, even if multiple clinicians are involved and multiple devices are used. Practices should designate a single billing provider for each patient’s RTM episode and coordinate internally.

In many cases, yes. CMS allows RTM or RPM to be billed in the same month as CCM, PCM, TCM, BHI, chronic pain management, and APCM when the time and services are distinct and not counted twice. The key is that you do not use the same minutes or identical activities to support more than one code family. Your documentation should make the dividing lines clear.

No. CMS requires an established relationship for RPM, but not for RTM. RTM services still must be medically reasonable and necessary, and you must be able to show how RTM data is used in the context of the patient’s care, but there is no explicit “established patient” requirement in RTM policy.

CPT 98978 (and, beginning in 2026, 98986 for 2–15 days) support RTM device supply for cognitive-behavioral therapy–oriented digital therapeutics. These codes are contractor-priced and payer adoption is still evolving. If you provide CBT-aligned digital therapy, confirm your MAC and commercial payer policies before relying on RTM CBT codes in your financial planning.

Yes. In 2026, CMS finalized a policy allowing General Supervision for Physical Therapist Assistants (PTAs) and Occupational Therapy Assistants (OTAs) in private practice. This means the supervising therapist does not need to be in the same building, allowing for centralized remote monitoring teams.

Auditors look for: documented patient consent; the specific RTM device or app (and its status as a medical device); the plan of care or episode definition; day-counts for device-supply codes; cumulative treatment-management time logs; dates, times, and modes of interactive communication; and notes showing how RTM data influenced clinical decisions. The more explicitly you connect RTM data to care-plan changes, the stronger your position in an audit.

For dates of service on or after January 1, 2026, RTM gains new device-supply codes for 2–15 days of monitoring (98984–98986) and a new 10–19 minute treatment-management code (98979). Existing device codes 98976/98977/98978 are revised to clearly represent 16–30 days of RTM in a 30-day period, and 98980/98981 continue to cover longer management time buckets. These changes give you more granular options for short episodes and shorter management engagements, while preserving the ability to bill longer, ongoing programs.

Yes, with caveats. You can bill multiple device codes (e.g., 98976 for respiratory and 98977 for MSK) if the patient has distinct medical needs for both. However, you can still only bill one set of management codes (98980/98981) per month, as management time is per-patient, not per-condition. Coordination is key to avoid "duplicate service" denials.