What CMS Actually Requires for RTM Billing

Remote Therapeutic Monitoring (RTM) has emerged as a powerful way to boost outcomes and create new revenue streams, yet confusion around the rules still keeps many clinics on the sidelines. A misplaced assumption or an incomplete webinar recap can turn into denied claims or, worse, repayment demands. To help you navigate the landscape confidently, we have distilled the official CMS guidance into six clear requirements and explained how Orva keeps each one on track.

1. You Must Use a Valid RTM Device

CMS states that RTM data must come from a medical device that monitors a musculoskeletal or respiratory condition. In practical terms, the device should have appropriate FDA clearance or be exempt under an applicable classification. Fitness trackers and self-reported mobile apps do not meet the standard because they rely on patient action rather than automated, system-captured data.

A compliant device records metrics such as range of motion or activity level in the background, then transmits that information securely without manual syncing. Orva’s technology stack incorporates only devices that satisfy these requirements, removing the risk of unbillable hardware and giving clinics confidence that every data point can stand up to audit review.

2. Data Must Be Collected for at Least 16 Days in a 30-Day Period

For codes like 98977, CMS mandates that the RTM device capture relevant information on no fewer than 16 separate days within the billing month. Those days need not be consecutive, but they must fall inside the same thirty-day window. Missing that threshold means the claim cannot be submitted, even if other clinical work was completed.

Orva surfaces real-time adherence dashboards that show exactly how many active days each patient has logged. Automated alerts flag anyone in danger of falling short so staff can intervene, coach the patient, or adjust the care plan before the billing cycle closes. This proactive oversight helps protect revenue and keeps patients progressing.

3. RTM Requires Patient Attestation for Certain Codes

Code 98975, which covers initial setup and patient education, calls for a documented attestation confirming that the patient received the device and understands its purpose. CMS treats this step as proof that the patient is an active participant, not a passive data source.

Orva builds attestation into the onboarding flow. When patients first activate their program, they acknowledge receipt of the device, confirm comprehension, and provide permission for remote monitoring. That record is stored automatically in the platform, eliminating the need for separate forms or manual uploads and ensuring that every future claim linked to the episode rests on solid ground.

4. Time-Based Codes Require 20 Minutes of Clinical Review

CPT 98980 pays for at least twenty minutes of professional time reviewing RTM data within each thirty-day cycle, plus one live interaction with the patient. The review should be substantive: providers must assess trends, evaluate adherence, and decide whether to maintain or modify the treatment plan. A brief glance at a dashboard is not enough.

Orva organizes patient-generated data into concise, clinically useful views so therapists and physicians can complete a thorough review without losing time to navigation. A built-in timer tracks the cumulative minutes spent on each patient, producing documentation that aligns exactly with CMS expectations and removing guesswork from the billing equation.

5. Only One Provider Can Bill RTM for a Patient per Period

CMS allows only one provider or billing entity to submit RTM claims for a given patient during any thirty-day period. If more than one clinic or specialist attempts to bill RTM for the same patient at the same time, those claims will likely be denied.

This makes it important for clinics to know exactly which provider is responsible for each patient’s RTM enrollment. Orva makes it easy to manage these assignments across your team. Within the platform, staff can clearly track which clinician is assigned to each patient and adjust as needed, reducing the risk of overlap or billing conflicts. This helps clinics stay organized, especially as RTM programs grow across multiple therapists or locations.

6. Documentation Must Justify Clinical Relevance

Each billed service must tie back to a legitimate clinical need. CMS expects providers to show how RTM insights influence care decisions, such as adjusting a home program, scheduling an earlier follow-up, or recommending additional therapy. Generic notes that simply restate the data are not enough.

Orva links every metric to the patient’s plan of care and provides structured fields for documenting actions taken. Providers can add narrative context, cite specific data points, and record decisions in a format that aligns with payer guidelines. This level of detail strengthens the medical-necessity argument and supports future audits.

Moving Forward with Confidence

RTM can transform both patient outcomes and practice revenue, but only if the program meets CMS standards every step of the way. By embedding device compliance, data thresholds, attestation, timed reviews, single-provider safeguards, and rich documentation into one platform, Orva removes the guesswork that so often derails new adopters.

Ready to build an RTM program that stays on the right side of every rule? Schedule a demo to see how Orva supports compliant, high-performing remote monitoring from day one.