Remote Therapeutic Monitoring (RTM) has rapidly evolved from a niche add-on to a core part of modern care delivery. As healthcare moves further into the digital era, RTM allows providers to monitor therapeutic adherence, patient progress, and outcomes remotely, without the need for frequent in-person visits.
But with new opportunities come new compliance challenges. In 2025 and beyond, understanding how RTM codes are structured, billed, and regulated will be essential for staying compliant and maximizing reimbursement under Medicare and commercial payers.
What Is Remote Therapeutic Monitoring (RTM)?
RTM refers to non-face-to-face services that use communications technology to monitor a patient’s adherence to prescribed therapy or response to treatment. Unlike Remote Physiologic Monitoring (RPM), which focuses on vital signs and biometric data, RTM is about behavioral and therapeutic engagement, such as how consistently patients perform their exercises, use medical devices, or follow treatment protocols.
RTM can apply to a wide range of conditions, but three specific categories have been codified under the Centers for Medicare & Medicaid Services (CMS):
- Respiratory system monitoring
- Musculoskeletal system monitoring
- Cognitive behavioral therapy (CBT) monitoring
Because RTM services are non-face-to-face, they are not classified as Medicare “telehealth” services under section 1834(m) of the Social Security Act. This means RTM isn’t subject to traditional telehealth restrictions, such as geographic or originating site limitations, giving providers more flexibility in how they deliver care.
For a deeper dive into eligibility and clinical requirements, see Eligibility Criteria for RTM Services.
RTM Codes: What’s Changing for 2025–2026
The current RTM code family includes CPT codes 98975, 98976, 98977, 98978, 98980, and 98981. These codes are used to capture device setup, data transmission, and clinical management time.
However, for Calendar Year (CY) 2026, the CPT Editorial Panel has introduced new and revised RTM codes to better reflect different levels of monitoring and time requirements.
| Category | CPT Codes | Description / Change |
|---|---|---|
| New Codes | 98XX4, 98XX5, 98XX7 | Created to describe RTM services requiring less than 16 days of data transmission per 30-day period and less than 20 minutes of communication per month. |
| Revised Codes | 98976, 98977, 98978 | Updated to specify minimum days of data transmission per 30-day period. |
All of these codes will be considered “new technology” and reviewed after three years of available data, projected for April 2030.
Billing and Valuation: What Providers Should Know
The RTM valuation process is primarily based on practice expense (PE) inputs, rather than physician work time. Here’s a breakdown of how CMS proposes to handle the main RTM code categories:
1. RTM Device Supply and Data Transmission Codes (PE-Only Codes)
These cover the digital transmission and equipment aspects of RTM. They include PE RVUs (practice expense relative value units) but no physician-work RVUs.
| CPT Code(s) | Proposed Valuation Rationale |
|---|---|
| 98XX5, 98977 | Based on Hospital Outpatient Prospective Payment System (OPPS) data. Both codes share the same valuation because the device is supplied for a full 30 days, regardless of the number of data days. |
| 98975 | CMS rejected RUCs proposed “program enrollment fee,” maintaining current PE inputs instead. |
| 98XX4, 98976 | To be determined by contractor pricing. |
| 98XX6, 98978 | 98XX6 proposed for contractor pricing; 98978 to retain contractor pricing. |
2. RTM Treatment Management Services (Timed Codes)
These represent the professional time spent managing and interpreting patient data.
- New code 98XX7: Proposed work RVU of 0.31, down from the RUC-recommended 0.66, reflecting shorter service duration (10 minutes versus 20 minutes for CPT 98980).
- CMS proposes clinical labor using the RN/LPN/MTA blend instead of physical therapy assistants, aligning with the dominant billing specialty, family medicine.
RTM in FQHCs and RHCs: Expanded Opportunities
Rural Health Clinics (RHCs) and Federally Qualified Health Centers (FQHCs) can now bill for RTM as a care coordination service, similar to Chronic Care Management (CCM) and Principal Care Management (PCM).
RTM services are paid separately from the RHC All-Inclusive Rate (AIR) or FQHC Prospective Payment System (PPS), based on the Medicare Physician Fee Schedule (PFS) national non-facility rate.
This change means providers in these settings can integrate RTM into their Advanced Primary Care Management (APCM) bundles, alongside other Communication Technology-Based Services (CTBS).
For a practical overview of how FQHCs and RHCs can take advantage of these payment pathways, see 2024 Medicare Billing Opportunities for FQHCs and RHCs with RPM and RTM Services.
Compliance and Documentation: Staying Aligned with CMS Standards
Even with these billing opportunities, compliance remains a core concern. Providers must ensure that RTM documentation clearly supports each billed service.
Here are the core compliance checkpoints for 2025–2026:
| Requirement | What It Means |
|---|---|
| Data Transmission Days | Track and document the exact number of monitoring days per 30-day period. |
| Time Tracking | Record minutes of communication and care management per month. |
| Device Validation | Use only FDA-cleared or contractor-approved devices. |
| Patient Consent | Obtain and document patient authorization for data collection and sharing. |
| Audit Readiness | Maintain timestamped logs and audit trails for CMS verification. |
Accurate documentation and device traceability not only protect reimbursement but also ensure continuity of care and data integrity.
The Future of RTM: From Pilot Programs to Mainstream Care
With ongoing CMS refinement, RTM is gaining wider adoption in chronic and behavioral health management. The 2026 CPT updates signal a push toward scalable, flexible remote care models that reward consistent patient engagement and validated outcomes.
Solution providers like DrKumo already align with these principles, providing HIPAA-compliant, FIPS 140-3 secure solutions that automate audit trails, enable FDA-cleared device integration, and help clinicians streamline both Remote Physiologic and Therapeutic Monitoring within a single interface.
Takeaways
RTM represents a major shift in how therapy-based remote care is delivered and reimbursed. Providers who understand the new code structures, valuation logic, and compliance rules will be better equipped to optimize both patient care and revenue cycles.
By staying proactive and adopting compliant, interoperable platforms like DrKumo, providers can confidently navigate the evolving RTM landscape, turning regulatory complexity into clinical opportunity.
While DrKumo specializes in Remote Patient Monitoring, our platform helps providers meet many of the same compliance, data security, and workflow needs shared with RTM programs. Contact DrKumo to see how our technology supports seamless documentation, billing readiness, and patient engagement across care models.
Disclaimer: This article is intended for informational purposes only and does not constitute legal, medical, or reimbursement advice. Providers should consult official CMS publications and professional advisors for guidance on billing and compliance.
