RTM for RHCs: CPT 98975-98981, the FDA-clearance gotcha, and the $100K-$220K/year opportunity most practices skip
Remote Therapeutic Monitoring (musculoskeletal, respiratory, behavioral health) pays comparably to RPM but doesn\u2019t require FDA-cleared medical-grade devices — smartphone apps and smartwatches qualify. Post-CY2024, RHCs and FQHCs can bill RTM directly. Most rural primary-care practices with chronic-pain, COPD, or MSK populations are leaving this revenue entirely unclaimed.
Frequently asked questions
What is Remote Therapeutic Monitoring (RTM) and how is it different from RPM?
Remote Therapeutic Monitoring uses CPT codes 98975-98981 to bill for non-physiologic monitoring — musculoskeletal system data, respiratory system data, cognitive behavioral therapy monitoring, and similar therapy-related tracking. RPM (Remote Patient Monitoring, CPT 99453-99458) monitors physiologic data — blood pressure, blood glucose, weight, SpO2, etc. The operational difference: RPM devices must be medical-grade (FDA-cleared, automatically transmitting data); RTM devices can include smartphone apps, smartwatches, or other self-reported data collection tools. Reimbursement is roughly comparable. For rural primary-care practices managing patients with asthma, COPD, chronic pain, MSK conditions, or medication-adherence challenges, RTM opens a billing category that doesn't require a prescribed FDA-cleared home monitor.
What do the RTM codes actually pay in 2026?
Five CPT codes, monthly billing: (1) 98975 — initial set-up and patient education on equipment use, ~$18 (one-time per episode of care). (2) 98976 — device supply with scheduled recording and/or programmed alerts, respiratory system, 30 days, ~$45. (3) 98977 — same, musculoskeletal system, 30 days, ~$45. (4) 98980 — treatment management services, first 20 minutes of clinical staff time per calendar month, ~$48. (5) 98981 — each additional 20 minutes, ~$38. A typical patient enrolled in RTM with monthly treatment management: 98980 + 98981 once = ~$86/month for 40 min of clinical staff time. For practices managing musculoskeletal/rehab populations or respiratory-condition populations, this is comparable to RPM economics.
Which patients qualify for RTM?
Two broad categories. (1) Musculoskeletal system: post-surgical rehab patients, chronic low back pain, knee/hip OA on conservative management, chronic pain on medication-management protocols, balance/fall-risk patients. (2) Respiratory system: asthma, COPD, sleep apnea, post-pneumonia recovery, chronic bronchitis. The code also explicitly contemplates cognitive behavioral therapy monitoring (e.g. mood tracking, medication-adherence app data for psychiatric patients), though that's billed under 98980/98981 without the device supply codes since the "device" is usually just a smartphone app. Coverage requires a written order from the billing provider, documented need for monitoring, and an appropriately-configured device or app that captures the relevant data.
What devices qualify as RTM devices?
The FDA does NOT require RTM devices to be FDA-cleared (unlike RPM). Qualifying devices include: (1) smartphone apps that capture patient-entered data (pain scores, medication adherence, symptom frequency); (2) smartwatches and fitness trackers when configured for therapy-relevant data collection; (3) pulmonary function monitoring apps / portable spirometers for respiratory RTM; (4) therapy-assistance apps that track exercise completion for MSK RTM; (5) medication-adherence tools (pillboxes with tracking, app-based reminders with log). Many practices use a single digital-health vendor whose app supports multiple RTM categories. The device must be capable of capturing and transmitting the data electronically — pen-and-paper self-report isn't sufficient.
Can RTM be billed alongside RPM for the same patient?
Yes, but only if the monitoring categories are clinically distinct and each is separately medically necessary. A patient with COPD on inhaler-adherence RTM and also on RPM blood-pressure monitoring for hypertension can generate both revenue streams simultaneously — distinct device types, distinct data streams, distinct clinical management. Time logs must be separate: a 20-min patient call about inhaler technique is RTM treatment-management time (98980); a different 20-min call about BP trending is RPM interactive-minute time (99457). Double-counting the same minutes across both codes is a denial trigger. Practices billing both should establish separate workflows + minute-tracking systems to keep the clinical distinction clean.
How did the CY2024 G0511 unbundling affect RTM for RHCs?
Significantly. Pre-CY2024, RHCs and FQHCs could NOT bill RTM directly — the care-management category was bundled into G0511. The CY2024 Physician Fee Schedule unbundled care management broadly, and RHCs / FQHCs can now bill 98975-98981 directly at standard Medicare-allowed amounts. This puts RTM on equal economic footing with RPM for rural primary-care practices. For RHCs that previously considered RPM but found the FDA-cleared-device requirement too operationally heavy, RTM is often the faster path — smartphone app + written order + minute tracking gets the same economics with less device infrastructure. See the <a href="/blog/rhc-care-management-cy2024-transition">CY2024 G0511 transition post</a> for the full unbundling picture.
What documentation does an RTM claim require?
Five elements: (1) written order from the billing provider specifying the monitoring category (MSK, respiratory, CBT) and medical necessity; (2) patient consent to services documented in the chart (can be verbal or written; must acknowledge cost-sharing); (3) device/app setup date (supports the 98975 one-time setup claim); (4) device-generated data log — the device or app must show 16+ days of transmitted data in the 30-day period for the device-supply codes (98976/98977), and the log must be retrievable for audit; (5) clinical-staff minute log for 98980/98981 treatment-management time, with per-encounter minutes and short task descriptions. The 16-day rule mirrors RPM's 99454 requirement and is the single most common RTM denial driver.
How do treatment-management minutes (98980/98981) work?
Same time-based pattern as RPM 99457. At least 20 minutes of cumulative clinical staff time in the calendar month, working on RTM-related activities: reviewing the device data, communicating with the patient about the data (phone, secure message, video), adjusting the care plan, coordinating with other providers. 20-39 min = 98980 alone (~$48). 40-59 min = 98980 + 98981 (~$86). 60+ min = 98980 + 98981 × 2 (~$124). The treatment-management code is where most RTM revenue actually lives — the monthly device-supply codes (98976/98977) are a base but the time-based management codes scale with delivered care. Most practices hit 20-40 min per engaged patient per month once the workflow is running.
Which specialties or practice types get the most value from RTM?
Four high-value profiles: (1) Primary care with a substantial population of chronic-pain / MSK / osteoarthritis patients — most PCPs have dozens of chronic-MSK patients who would benefit. (2) Pulmonology or PCPs with a COPD/asthma-heavy panel — respiratory RTM fits the workflow. (3) Orthopedic or sports-medicine practices managing post-surgical rehab — RTM lets them bill for the telehealth-based post-op check-ins that were previously uncompensated. (4) Behavioral-health integrated primary care using RTM for CBT protocol monitoring / medication adherence. For rural PCPs with a broad chronic-condition panel, combining RPM (BP, BG, SpO2 monitoring) with RTM (MSK pain, respiratory adherence) captures meaningful recurring revenue without dramatically expanding workflow.
What are the most common RTM billing errors?
Five common denial patterns: (1) Missing 16-day transmission threshold on the 98976/98977 device code — same rule as RPM's 99454. Patient has to transmit data on 16+ days in the 30-day period; 15 days = no billable device code that month. (2) No written provider order on file. RTM requires an explicit order; an implied order from a visit note isn't sufficient. (3) Treatment-management minutes not documented or documented in block-summary form instead of per-encounter. (4) Double-counting minutes with RPM 99457 or CCM 99490 in the same month. (5) Using an app that doesn't technically qualify as a "device" — purely pen-and-paper self-reported data doesn't cut it, data must be electronically transmitted. Tightening the workflow brings denial rates under 5% typically.