CPT Code 98975: Remote Therapeutic Monitoring Setup and Patient Education

What is CPT Code 98975?

CPT code 98975 represents the initial setup and patient education component of Remote Therapeutic Monitoring (RTM). This code covers the comprehensive onboarding process that establishes patients in an RTM program, including device orientation, education on proper use, and initial care plan setup.

Code Description: Remote therapeutic monitoring (RTM) device(s) setup and patient education on use of RTM device(s); first 16 days
Billing Frequency: Once per treatment episode
Average National Reimbursement: $19.97 (rates vary by region and payer)

Brief History of RTM Codes

The RTM code set was introduced by the Centers for Medicare & Medicaid Services (CMS) in 2022 as part of an effort to expand remote care capabilities beyond traditional telehealth. Unlike Remote Patient Monitoring (RPM) codes that focus on vital signs and chronic disease management, RTM codes were specifically designed for musculoskeletal conditions and therapeutic interventions.

The creation of these codes recognized the growing need for extended care beyond clinic walls, particularly following the COVID-19 pandemic when home-based rehabilitation became essential. The four-code RTM framework (98975, 98977, 98980, 98981) provides a comprehensive billing structure that supports both technology provision and clinical management services.

Key Requirements for Billing 98975

16-Day Minimum Usage
The most critical requirement for billing 98975 is documenting at least 16 days of patient engagement with the RTM device within a 30-day period. This threshold ensures meaningful patient participation and clinical value before reimbursement occurs.

Medical Device Classification
Only platforms classified as medical devices are eligible for RTM billing. Consumer fitness apps, general wellness platforms, or non-medical software cannot support legitimate 98975 claims. The technology must meet FDA standards and be specifically designed for therapeutic monitoring.

Initial Setup Documentation
Billing 98975 requires documentation of:

  • Patient education on device use and program expectations

  • Initial therapeutic goals and care plan establishment

  • Device configuration and connectivity verification

  • Patient consent and program enrollment confirmation

One-Time Billing Per Episode
Unlike other RTM codes that can be billed monthly, 98975 is billed only once per treatment episode. Starting a new episode requires a significant change in condition, new diagnosis, or substantial modification to the treatment approach.

Relationship to Other RTM Codes
CPT 98975 serves as the foundation for all other RTM billing. Without proper 98975 documentation and the 16-day usage requirement, practices cannot bill the recurring codes:

  • 98977: Monthly device supply and data transmission

  • 98980: Clinical management services (first 20 minutes monthly)

  • 98981: Additional clinical management time

The 16-day usage period required for 98975 also establishes the baseline for ongoing 98977 billing, creating a connected billing cycle throughout the episode of care.

Documentation Best Practices

Required Elements

  • Date and time of initial setup session

  • Staff member who provided patient education

  • Specific education topics covered

  • Patient's demonstrated understanding of device use

  • Initial care plan and therapeutic goals

  • Device serial numbers and configuration details

Clinical Oversight
While 98975 doesn't require a physician's direct involvement, appropriate clinical oversight must be documented. This typically includes:

  • Supervising practitioner's review and approval of the RTM plan

  • Integration with the overall plan of care

  • Clear therapeutic rationale for RTM implementation

Common Billing Errors and How to Avoid Them

Premature Submission
The most frequent error is submitting 98975 claims before completing the full 16-day usage requirement. Claims should only be submitted after the usage threshold is confirmed, not at the time of initial setup.

Duplicate Episode Billing
Attempting to bill 98975 multiple times for the same patient without a legitimate new episode. Minor adjustments to existing programs don't qualify as new episodes.

Inadequate Documentation
Failing to document the initial setup process thoroughly. Each 98975 claim should have clear evidence of patient education and program establishment.

Medical Device Compliance
Using non-qualifying technology platforms that don't meet medical device standards, leading to claim denials and potential audit issues.

Payer Considerations

Medicare Coverage
Medicare consistently covers 98975 when properly documented and billed. The code is not subject to therapy caps or authorization requirements, making it more accessible than traditional therapy services.

Commercial Insurance
Coverage varies significantly among commercial payers. Best practices include:

  • Verifying RTM benefits before patient enrollment

  • Understanding each payer's specific documentation requirements

  • Confirming reimbursement rates, which may differ from Medicare amounts

Medicare Advantage
Most Medicare Advantage plans follow CMS guidelines but may require additional documentation or prior authorization. Contact plans directly to understand their specific policies.

Revenue Impact and Practice Benefits

Financial Opportunity
At an average reimbursement of approximately $20 per patient, 98975 provides immediate revenue upon program enrollment. When combined with ongoing RTM codes, practices can generate $150–200 or more per patient per episode.

Operational Efficiency
Properly implemented 98975 processes create standardized patient onboarding that reduces long-term administrative burden while ensuring compliance across all RTM services.

Patient Engagement Foundation
The comprehensive education and setup provided through 98975 directly impacts success rates for ongoing RTM programs, leading to better adherence and clinical outcomes.

Compliance and Audit Preparedness

Key Documentation Points

  • Signed patient consent for RTM participation

  • Detailed education checklist completion

  • Device assignment and configuration records

  • Integration with existing plan of care

  • Clear therapeutic justification

Audit Response Strategy
Maintain organized records that clearly demonstrate the educational value provided and device setup completed. Strong 98975 documentation supports the entire RTM episode if questioned by payers.

Looking Ahead: 2026 Policy Changes

Proposed changes for 2026 may reduce the 16-day requirement and introduce more flexible billing options. However, the fundamental structure of 98975 as the episode initiation code is expected to remain, making current investment in compliant processes valuable for long-term success.

Understanding and properly implementing CPT 98975 creates the foundation for successful RTM programs that deliver clinical value while generating sustainable revenue streams for your practice.