How to Bill CPT 98975 and Meet the 16-Day Compliance Rule
Current Procedural Terminology (CPT) code 98975 is one of the most important billing codes for clinics using Remote Therapeutic Monitoring (RTM). It covers the initial setup of an RTM program, including patient education, and can only be billed once per episode of care.
Many clinics miss out on reimbursement because they do not meet the 16-day requirement or submit incomplete documentation. This guide explains how to bill CPT 98975 correctly, stay compliant, and avoid common mistakes.
What CPT 98975 Covers
CPT 98975 applies to the initial setup and patient education required to begin Remote Therapeutic Monitoring. It is billed when a clinician:
Provides the RTM device or digital platform
Trains the patient on how to use it
Establishes the monitoring plan for a specific condition, most often musculoskeletal rehabilitation
The device must be capable of transmitting data, and the service must be tied to a clinical goal — such as post-operative recovery or chronic condition management.
Understanding the 16-Day Rule
To bill CPT 98975, the Centers for Medicare & Medicaid Services (CMS) and most commercial payers require that the patient generates at least 16 days of data within the first 30 days of monitoring.
This means the patient must actively interact with the RTM platform for 16 separate days during that first month. The days do not need to be consecutive, but they must fall within the same 30-day window.
Examples of qualifying engagement include:
Logging into the platform and completing exercises
Recording pain scores or symptoms
Uploading data from an integrated device
Pro tip: Use an RTM system that automatically tracks and timestamps engagement to simplify compliance.
Reimbursement Rates
Reimbursement for CPT 98975 varies by payer:
CMS national average: $20.63
Commercial and motor vehicle accident (MVA) insurance: Often higher, with many clinics setting their fee schedule at $50 to capture higher-paying contracts
Always confirm your contracted rates with each payer and update your fee schedule regularly.
Step-by-Step Billing Process
Verify patient eligibility – Confirm that RTM services are covered under the patient’s benefits.
Provide setup and education – Document the device issued, instructions given, and start date.
Track engagement – Ensure the patient meets the 16-day activity requirement within 30 days.
Prepare the claim – Submit CPT 98975 with the correct place of service (11) and any required modifiers.
Attach documentation – Include the billing report, daily engagement logs, and patient education notes.
Modifiers and Special Rules
KX Modifier – Required if the patient is at or near the therapy cap.
CQ Modifier – Required if a physical therapist assistant (PTA) provides more than 10% of the setup and education time.
No co-pay – This is not considered a clinic visit, so no co-pay or authorized visit should be charged.
Mistakes to Avoid
Many denials happen for avoidable reasons, such as:
Billing before the 16-day requirement is met
Missing documentation of the setup or education
Using the wrong date of service (use the claim submission date)
Forgetting to apply necessary modifiers
How Orva Helps You Bill CPT 98975 Correctly
Orva’s Remote Therapeutic Monitoring platform automatically tracks patient engagement, generates compliant billing reports, and stores all education records in one place. This means your billing team always has the documentation needed to submit a clean claim and maximize reimbursement.
Key takeaway: CPT 98975 can be a consistent revenue source when billed correctly, but it requires careful tracking, complete documentation, and adherence to the 16-day rule. With the right workflow and tools, your clinic can stay compliant and get paid without added administrative burden.
Ready to learn how Orva helps you run RTM the right way? Schedule a demo and we’ll walk you through exactly how it works.