Common Billing Mistakes for 98975 and 98977 and How to Avoid Them
Current Procedural Terminology (CPT) codes 98975 and 98977 are two of the most widely used codes in Remote Therapeutic Monitoring (RTM). CPT 98975 covers the initial setup and patient education, while CPT 98977 covers ongoing device supply and monitoring for musculoskeletal conditions.
Both codes can provide significant revenue when billed correctly — but simple mistakes can delay payment or lead to denials. This guide highlights the most common errors billing teams make and how to avoid them.
Mistake 1 — Billing Before the 16-Day Rule Is Met
The problem: Both CPT 98975 and CPT 98977 require at least 16 days of patient data collection within a 30-day period. Submitting a claim before the 16-day threshold is reached is one of the fastest ways to get denied.
How to avoid it: Track engagement daily and only submit claims after verifying that the patient has reached the 16-day requirement. Use an RTM platform that automatically logs and timestamps activity so you have complete records.
Mistake 2 — Missing or Incomplete Documentation
The problem: Payers require proof that the service was provided, including the type of device issued, patient education details, and activity logs. Missing any of these details can result in a denial.
How to avoid it: Include all required documentation with your claim. For CPT 98975, this means device setup records, patient education notes, and the start date. For CPT 98977, include device usage logs for the 30-day monitoring period and notes on how the data was used in patient care.
Mistake 3 — Confusing 98975 and 98977
The problem: Some clinics mistakenly bill CPT 98977 for the initial setup or CPT 98975 for ongoing monitoring. Each code has a distinct purpose.
How to avoid it: Bill CPT 98975 once per episode of care for initial setup and patient education. Bill CPT 98977 every 30 days for ongoing device supply and monitoring — after the initial setup period.
Mistake 4 — Incorrect Use of Modifiers
The problem: Modifiers such as KX and CQ are sometimes omitted or applied incorrectly. For example, adding a CQ modifier to CPT 98977 when it is not required can cause confusion and slow down claim processing.
How to avoid it:
KX modifier — Use when the patient is at or near the therapy cap and medical necessity is documented.
CQ modifier — Required for CPT 98975 if a physical therapist assistant (PTA) provides more than 10% of the setup and education, and for CPT 98980 or 98981 if a PTA contributes more than 10% of treatment management time. Not required for CPT 98977.
Mistake 5 — Using the Wrong Date of Service
The problem: Some billing teams submit the start date of monitoring as the date of service. Most payers require the date you submit the claim, not the program start date.
How to avoid it: Always use the claim submission date as the date of service for RTM CPT codes unless your payer’s policy states otherwise.
Mistake 6 — Charging a Co-Pay for RTM
The problem: RTM codes are not considered in-person visits. Charging a co-pay can lead to patient disputes and compliance issues.
How to avoid it: Exclude RTM CPT codes from co-pay requirements and ensure billing policies reflect this distinction.
How Orva Prevents Billing Mistakes
Orva’s RTM platform automatically tracks patient engagement, generates complete billing reports, and flags missing modifiers or documentation before claims are submitted. By using Orva, clinics can reduce denials, accelerate payments, and stay compliant with CMS and commercial payer rules.
Key Takeaway
Most billing mistakes for CPT 98975 and CPT 98977 happen because of missed requirements, incomplete documentation, or confusion about when to bill each code. With the right tracking tools, workflows, and payer knowledge, these errors are easy to avoid — ensuring your RTM program delivers maximum revenue with minimal administrative burden.
Tired of second-guessing your RTM compliance? Book a demo to discover how Orva's automated workflows ensure you stay within CMS guidelines every step of the way.