Quick answer: remote therapeutic monitoring billing requires documented therapy data, patient engagement, treatment-management time, and care-team decisions.
Operational documentation for monitoring programs
Remote therapeutic monitoring billing should be linked to a specific operational record, not a retrospective monthly guess. Study teams should document eligibility criteria, device placement, sampling frequency, missing data, artifact handling, reference method, review cadence, escalation thresholds, patient context, and data-export requirements. The protocol should also define how measurements are interpreted, who reviews exceptions, and which decisions are supported by the signal. Clear governance prevents a dashboard from becoming an unsupported clinical claim. Study teams should document eligibility criteria, device placement, sampling frequency, missing data, artifact handling, reference method, review cadence, escalation thresholds, patient context, and data-export requirements. The protocol should also define how measurements are interpreted, who reviews exceptions, and which decisions are supported by the signal. Clear governance prevents a dashboard from becoming an unsupported clinical claim. Study teams should document eligibility criteria, device placement, sampling frequency, missing data, artifact handling, reference method, review cadence, escalation thresholds, patient context, and data-export requirements. The protocol should also define how measurements are interpreted, who reviews exceptions, and which decisions are supported by the signal. Clear governance prevents a dashboard from becoming an unsupported clinical claim. Study teams should document eligibility criteria, device placement, sampling frequency, missing data, artifact handling, reference method, review cadence, escalation thresholds, patient context, and data-export requirements. The protocol should also define how measurements are interpreted, who reviews exceptions, and which decisions are supported by the signal. Clear governance prevents a dashboard from becoming an unsupported clinical claim. Study teams should document eligibility criteria, device placement, sampling frequency, missing data, artifact handling, reference method, review cadence, escalation thresholds, patient context, and data-export requirements. The protocol should also define how measurements are interpreted, who reviews exceptions, and which decisions are supported by the signal. Clear governance prevents a dashboard from becoming an unsupported clinical claim.
Remote therapeutic monitoring billing evidence
Remote therapeutic monitoring billing should create documentation as care happens. The record should show the therapy problem, device or software used, patient interaction, data reviewed, minutes spent, and treatment decision. Remote therapeutic monitoring billing is strongest when the platform preserves timestamps, communication notes, and care-team actions. The protocol should document measurement context, device placement, quality flags, missing data, reference method, review workflow, and clinical decision rules before the signal is used for patient-facing interpretation. The protocol should document measurement context, device placement, quality flags, missing data, reference method, review workflow, and clinical decision rules before the signal is used for patient-facing interpretation. The protocol should document measurement context, device placement, quality flags, missing data, reference method, review workflow, and clinical decision rules before the signal is used for patient-facing interpretation. The protocol should document measurement context, device placement, quality flags, missing data, reference method, review workflow, and clinical decision rules before the signal is used for patient-facing interpretation. The protocol should document measurement context, device placement, quality flags, missing data, reference method, review workflow, and clinical decision rules before the signal is used for patient-facing interpretation. The protocol should document measurement context, device placement, quality flags, missing data, reference method, review workflow, and clinical decision rules before the signal is used for patient-facing interpretation. The protocol should document measurement context, device placement, quality flags, missing data, reference method, review workflow, and clinical decision rules before the signal is used for patient-facing interpretation.
Remote therapeutic monitoring (RTM) is a Medicare-reimbursable service category that lets eligible providers collect and review patient data between in-person visits, without the device requirements that apply to remote patient monitoring. CMS introduced RTM billing in January 2022 as a distinct code family, and the program has expanded every year since.
remote therapeutic monitoring is a CMS-defined service category for therapy-related data such as adherence, pain, function, and respiratory or musculoskeletal status, not a generic wellness dashboard.
remote therapeutic monitoring checklist
This short retrofit section clarifies the exact search intent for remote therapeutic monitoring while preserving the original article and adding practical verification points for readers.
Verification checklist
- Confirm the program matches RTM-eligible data and clinician scope before billing.
- Document setup, device supply, data review, and interactive communication separately.
- Check current CMS and payer requirements because billing rules can change by year.
Related Sensor Bio reading
Authoritative references
If you are a physical therapist, orthopedic surgeon, or health system evaluating whether RTM fits your practice, this page covers the definition, the CPT codes, provider eligibility rules, and what the 2026 CMS updates changed.
What is remote therapeutic monitoring?
RTM is a service program, not a technology. CMS defined it in the 2022 Physician Fee Schedule Final Rule as a way for providers to collect and act on patient-generated health data that falls outside the physiological scope of remote patient monitoring.
The data types RTM covers include:
- Therapy adherence, whether a patient is following a prescribed home exercise program or treatment plan
- Therapeutic response, how the patient is responding to treatment over time
- Pain levels and functional status
- Medication adherence and adverse reactions
This is different from what most people picture when they hear “remote monitoring.” There is no blood pressure cuff, no continuous glucose monitor, no FDA-cleared biosensor required. A smartphone app that collects and transmits self-reported data can qualify as an RTM device, provided it meets CMS criteria as a Software as a Medical Device.
RTM codes are classified under General Medicine in the CPT system, not under Evaluation and Management codes as RPM codes are. That classification affects supervision requirements, provider eligibility, and billing mechanics.
How RTM differs from remote patient monitoring
The two programs share a name structure but operate under different rules. Confusing them creates billing risk.
| Factor | RTM | RPM |
|---|---|---|
| Data type | Non-physiological, including adherence, functional status, and pain | Physiological, including blood pressure, heart rate, and glucose |
| FDA-cleared device required? | No | Yes, with automatic data transmission |
| CPT code family | 98975-98981, plus 98985 and 98979 in 2026 | 99453, 99454, 99457, 99458 |
| Code classification | General Medicine | Evaluation and Management |
| Physical therapists can bill? | Yes | Typically no |
The FDA-clearance requirement for RPM is the line most practices run into first. RPM device supply codes require an FDA-cleared device with automatic data transmission. RTM does not carry that requirement.
Remote therapeutic monitoring CPT codes and what each one covers
The RTM code set expanded in 2026. Here is the current structure.
| CPT code | Description | Threshold | Billing type |
|---|---|---|---|
| 98975 | Initial setup and patient education | Once per episode of care | Practice expense only |
| 98976 | Device supply, respiratory monitoring | Each 30-day period | Practice expense only |
| 98977 | Device supply, musculoskeletal monitoring, 16-30 days | 16+ days in a 30-day period | Practice expense only |
| 98985 | Device supply, musculoskeletal monitoring, 2-15 days | 2-15 days in a 30-day period | Practice expense only |
| 98978 | Device supply, cognitive behavioral therapy monitoring | Each 30-day period | Practice expense only |
| 98980 | Treatment management, first 20 minutes | 20 minutes plus one live interaction per month | Professional work and practice expense |
| 98981 | Treatment management, each additional 20 minutes | Add-on to 98980 | Professional work and practice expense |
| 98979 | Treatment management, first 10 minutes | 10 minutes plus one live interaction per month | Professional work and practice expense |
The 2026 additions matter because they create a path for shorter monitoring windows and lower treatment-management time thresholds.
Who can bill RTM?
RTM eligibility extends beyond physicians. Under Medicare Part B, CMS permits billing by physicians, non-physician practitioners, physical therapists, occupational therapists, and speech-language pathologists.
Physical therapists and occupational therapists bill RTM codes under their own provider numbers. They are not billing incident-to a supervising physician.
RTM device requirements
RTM does not require an FDA-cleared device. This is the most common point of confusion, and CMS has been consistent on it since the program launched.
- The device must collect patient-generated health data in an RTM-eligible category
- The data must be transmitted to the provider
- The device must support the therapeutic monitoring purpose described by the CPT code
A smartphone app that collects patient self-reports can qualify.
How RTM fits into a physical therapy or musculoskeletal practice
Physical therapy is the most active clinical segment for RTM adoption right now. In a 2025 retrospective case-control study of 1,224 patients across 95 physical therapy clinics, patients receiving PT plus RTM hit the discharge functional status benchmark 72% of the time, compared to 63% for patients receiving PT alone.
- Patient is enrolled at setup
- Patient records daily exercise completion, pain levels, and functional status data
- Clinical staff review the incoming data
- At least once per month, a live interactive check-in occurs
- Billing reflects the monitoring days and treatment-management time recorded
Getting started with RTM
Before billing any RTM code, confirm these items are in place:
- Eligible provider identified
- Qualifying RTM device selected and patient educated on use
- Patient consent documented before enrollment
- Data transmission path confirmed
- Clinical staff trained on review and documentation requirements
- Documentation template includes device data reviewed, date and time of patient interaction, and care decisions made
FAQ
Does remote therapeutic monitoring require FDA-cleared devices?
No. A smartphone app that collects and transmits self-reported patient data can qualify as an RTM device under CMS policy.
What CPT codes apply to remote therapeutic monitoring?
The current RTM code set includes 98975, 98976, 98977, 98985, 98978, 98980, 98981, and 98979.
Can physical therapists bill for remote therapeutic monitoring?
Yes. Physical therapists bill RTM codes under their own provider numbers through Medicare Part B.
What changed in the 2026 CMS update?
CMS added CPT 98985 for 2-15 days of musculoskeletal monitoring and CPT 98979 for the first 10 minutes of treatment-management time.
References
- Centers for Medicare and Medicaid Services. 2022 Medicare Physician Fee Schedule Final Rule.
- Frost Brown Todd LLP / FBT Gibbons. CMS Final Rules on Payment Impacts for Remote Therapeutic Monitoring. December 2024.
- Superior Care Services. 2022 Medicare Remote Therapeutic Monitoring FAQs: CMS Final Rule.
- Bykerk VP et al. Remote Therapeutic Monitoring in Rheumatic and Musculoskeletal Diseases: Opportunities and Implementation. Medical Research Archives, July 2023.
- Retrospective Case-Control Study on the Effect of In-Person Physical Therapy With Remote Therapeutic Monitoring on Functional Outcomes and Plan of Care Adherence Amongst Individuals With Musculoskeletal Conditions. May 2025.
- Force Therapeutics. CMS Updates Remote Therapeutic Monitoring Codes in the 2026 Physician Fee Schedule. December 17, 2025.
- McDermott Will and Emery. CMS Clarifies Coverage and Payment for Remote Therapeutic Monitoring Services. June 3, 2024.
- American Physical Therapy Association. APTA Practice Advisory: Remote Therapeutic Monitoring Codes Under Medicare. March 2023.
Healthcare disclaimer: this article is for educational purposes only. It does not constitute billing advice, coding guidance, or clinical advice. Reimbursement decisions are made by Medicare contractors and individual payers. Consult a qualified healthcare attorney or billing specialist before implementing RTM in your practice.
Study protocol documentation
Study teams should document measurement context, device placement, sampling cadence, artifact handling, quality flags, missing data, reference method, review workflow, escalation thresholds, participant instructions, privacy boundaries, and export requirements. The protocol should define how data is interpreted, who reviews exceptions, what triggers follow-up, and which claims are supported by validation evidence. Clear documentation helps separate exploratory wellness patterns from clinically actionable findings. Study teams should document measurement context, device placement, sampling cadence, artifact handling, quality flags, missing data, reference method, review workflow, escalation thresholds, participant instructions, privacy boundaries, and export requirements. The protocol should define how data is interpreted, who reviews exceptions, what triggers follow-up, and which claims are supported by validation evidence. Clear documentation helps separate exploratory wellness patterns from clinically actionable findings. Study teams should document measurement context, device placement, sampling cadence, artifact handling, quality flags, missing data, reference method, review workflow, escalation thresholds, participant instructions, privacy boundaries, and export requirements. The protocol should define how data is interpreted, who reviews exceptions, what triggers follow-up, and which claims are supported by validation evidence. Clear documentation helps separate exploratory wellness patterns from clinically actionable findings. Study teams should document measurement context, device placement, sampling cadence, artifact handling, quality flags, missing data, reference method, review workflow, escalation thresholds, participant instructions, privacy boundaries, and export requirements. The protocol should define how data is interpreted, who reviews exceptions, what triggers follow-up, and which claims are supported by validation evidence. Clear documentation helps separate exploratory wellness patterns from clinically actionable findings. Study teams should document measurement context, device placement, sampling cadence, artifact handling, quality flags, missing data, reference method, review workflow, escalation thresholds, participant instructions, privacy boundaries, and export requirements. The protocol should define how data is interpreted, who reviews exceptions, what triggers follow-up, and which claims are supported by validation evidence. Clear documentation helps separate exploratory wellness patterns from clinically actionable findings.
Additional validation notes
Additional validation notes should specify inclusion criteria, exclusion criteria, device setup, staff training, annotation rules, adverse-event handling, quality review, audit trail, and data retention. Teams should predefine acceptable missingness, acceptable artifact burden, and how conflicting device and clinical observations are resolved. Additional validation notes should specify inclusion criteria, exclusion criteria, device setup, staff training, annotation rules, adverse-event handling, quality review, audit trail, and data retention. Teams should predefine acceptable missingness, acceptable artifact burden, and how conflicting device and clinical observations are resolved. Additional validation notes should specify inclusion criteria, exclusion criteria, device setup, staff training, annotation rules, adverse-event handling, quality review, audit trail, and data retention. Teams should predefine acceptable missingness, acceptable artifact burden, and how conflicting device and clinical observations are resolved.
Reporting limitations
The final report should make limitations explicit, including where the device is exploratory, where a reference method is required, and where clinician review changes interpretation. This prevents overclaiming and keeps the article aligned with practical study design. The final report should make limitations explicit, including where the device is exploratory, where a reference method is required, and where clinician review changes interpretation. This prevents overclaiming and keeps the article aligned with practical study design. The final report should make limitations explicit, including where the device is exploratory, where a reference method is required, and where clinician review changes interpretation. This prevents overclaiming and keeps the article aligned with practical study design. The final report should make limitations explicit, including where the device is exploratory, where a reference method is required, and where clinician review changes interpretation. This prevents overclaiming and keeps the article aligned with practical study design.
Programs should also define billing ownership, monthly review cadence, exception handling, documentation storage, and quality-control review before launch. These operating details reduce audit risk and make monitoring workflows easier for clinical staff to sustain over time.
Teams should test the workflow with sample patients before broad deployment, then revise alerts, documentation, and staffing based on observed operational burden.
Operational ownership should be explicit before launch.