CPT Code 98981: Additional Remote Therapeutic Monitoring Management Time
What is CPT Code 98981?
CPT code 98981 is an add-on code that captures additional clinical management time beyond the initial 20 minutes covered by 98980. This code enables comprehensive RTM oversight for complex patients or situations requiring extended clinical attention, ensuring providers are compensated for the full scope of professional time invested in remote care.
Code Description: Remote therapeutic monitoring (RTM) treatment management services, physician or other qualified health care professional time in a calendar month requiring interactive communication with the patient/caregiver during the month; each additional 20 minutes
Billing Frequency: Multiple times per calendar month (as add-on to 98980)
Average National Reimbursement: $39.95 per 20-minute increment (rates vary by region and payer)
Add-On Code Structure and Dependencies
Mandatory Base Code Requirement
98981 cannot be billed independently. It must always be submitted alongside 98980 in the same calendar month. The billing relationship works as follows:
98980: First 20 minutes of RTM management (required base)
98981: Each additional 20-minute increment (add-on only)
Multiple Unit Billing
Unlike 98980 which is limited to once per month, 98981 can be billed multiple times within the same calendar month, depending on actual clinical time invested:
21–40 minutes total = 98980 + one unit of 98981
41–60 minutes total = 98980 + two units of 98981
61–80 minutes total = 98980 + three units of 98981
Time Accumulation Rules
Clinical time for 98981 can be accumulated throughout the calendar month but must be documented in precise 20-minute increments. Partial increments cannot be billed. Providers must reach the full 20-minute threshold for each 98981 unit.
Clinical Activities Qualifying for 98981
Extended Data Analysis
Complex patients may require additional time for:
Comprehensive review of multiple data streams
Analysis of concerning trends or regression patterns
Detailed comparison of pre/post intervention metrics
Integration of RTM data with other clinical assessments
Enhanced Patient Communication
Additional time may be needed for:
Extended patient education on program modifications
Motivational interviewing for adherence improvement
Complex problem-solving for barriers to participation
Family or caregiver education and involvement
Care Coordination Activities
98981 time may include:
Consultation with other healthcare team members
Coordination with referring physicians based on RTM findings
Integration of RTM insights with ongoing treatment plans
Documentation of complex clinical decision-making processes
Clinical Documentation Requirements
Extended clinical oversight may require additional time for:
Comprehensive progress note creation
Detailed care plan modifications
Insurance communication regarding RTM findings
Preparation of clinical summaries for team communication
Time Tracking and Documentation Excellence
Precise Time Logging
Each 98981 unit requires meticulous documentation:
Exact start and stop times for clinical activities
Specific activities performed during each time period
Clear separation between base (98980) and add-on (98981) time
Running totals throughout the calendar month
Activity-Specific Documentation
Document the clinical necessity for extended time:
Complex patient presentations requiring additional analysis
Multiple clinical issues identified through RTM data
Extended patient communication needs
Coordination requirements with other providers
Monthly Time Reconciliation
Establish systems to track and verify total monthly time:
Daily time log maintenance
Weekly running totals
Monthly reconciliation before billing
Clear audit trail for each claimed increment
Patient Populations Most Likely to Generate 98981 Time
Complex Medical Histories
Patients with multiple comorbidities may require extended RTM oversight:
Diabetes with orthopedic conditions
Cardiovascular disease impacting rehabilitation
Chronic pain affecting exercise adherence
Multiple joint replacements or surgeries
High-Risk Recovery Situations
Certain clinical scenarios naturally require more intensive monitoring:
Post-surgical complications or concerns
Slow progress or plateau situations
Recurring symptoms or functional decline
Safety concerns with home exercise programs
Psychosocial Complexity
Patients with additional challenges may need extended support:
Limited health literacy requiring extended education
Language barriers necessitating longer communications
Anxiety or depression affecting program participation
Complex family dynamics impacting compliance
Technology Challenges
Some patients require additional clinical time for:
Repeated education on device use
Troubleshooting technical difficulties
Interpretation of inconsistent data patterns
Motivation and re-engagement strategies
Provider Considerations and Limitations
Physical Therapist Assistant (PTA) Billing Impact
When PTAs provide substantial portions of 98981 services:
CQ modifier must be applied to each 98981 unit
15% reduction in Medicare reimbursement applies
Clear documentation of PTA vs. supervising therapist time required
Supervision requirements must be maintained throughout
Qualified Healthcare Professional Requirements
98981 maintains the same provider qualification standards as 98980:
Licensed physical therapists
Licensed occupational therapists
Physicians
Other qualified healthcare professionals per CMS guidelines
Appropriate supervision for support staff
Clinical Justification Standards
Each 98981 unit must demonstrate legitimate clinical necessity:
Clear rationale for extended time requirements
Evidence of complex clinical decision-making
Documentation of patient-specific factors requiring additional attention
Demonstration of professional judgment throughout extended time
Revenue Optimization and Efficiency
Strategic Time Management
Maximize clinical value while ensuring accurate billing:
Batch complex patient reviews when possible
Use standardized templates for common extended activities
Implement efficient communication protocols
Leverage technology for streamlined documentation
Patient Selection Criteria
Identify patients most likely to benefit from extended RTM management:
Complex medical presentations
History of adherence challenges
Multiple provider coordination needs
High-risk recovery situations
Clinical Workflow Integration
Incorporate 98981 planning into practice operations:
Schedule dedicated time for complex RTM reviews
Train staff to recognize situations requiring extended oversight
Develop protocols for escalating patients to extended management
Create systems for tracking and predicting 98981 needs
Common Billing Errors and Solutions
Inadequate Time Documentation
Error: Claiming 98981 units without precise time tracking
Solution: Implement systematic time logging with activity-specific documentation
Billing Without Base Code
Error: Attempting to bill 98981 without corresponding 98980
Solution: Always verify 98980 requirements are met before adding 98981 units
Partial Increment Billing
Error: Billing 98981 for less than 20 minutes of additional time
Solution: Accumulate time throughout the month to reach full 20-minute increments
Insufficient Clinical Justification
Error: Billing extended time without documenting clinical necessity
Solution: Focus documentation on complex clinical decision-making and patient-specific factors
Payer-Specific Considerations
Medicare Coverage
Medicare covers 98981 when properly documented alongside 98980:
Same “sometimes therapy” benefits as other RTM codes
No prior authorization required
Must meet all time and documentation requirements
Subject to same audit standards as base RTM codes
Commercial Insurance Variability
Commercial payers may have different approaches to 98981:
Some automatically follow Medicare guidelines
Others may limit the number of 98981 units per month
Prior authorization may be required for extensive RTM management
Documentation requirements may exceed Medicare standards
Medicare Advantage Considerations
Medicare Advantage plans typically accept 98981 but may require:
Enhanced justification for extended time needs
Regular reporting of clinical outcomes
Specific documentation of complex patient factors
Periodic review of high-utilization patients
Quality Assurance and Compliance
Internal Audit Procedures
Regular review of 98981 billing should verify:
Accurate time calculation and documentation
Legitimate clinical justification for extended time
Proper add-on code usage with base 98980
Provider qualification and supervision compliance
External Audit Preparedness
Maintain comprehensive documentation including:
Detailed time logs with specific clinical activities
Clear justification for extended management needs
Evidence of complex clinical decision-making
Patient-specific factors requiring additional attention
Benchmark Monitoring
Track 98981 usage patterns to ensure appropriate utilization:
Percentage of RTM patients requiring extended time
Average 98981 units per complex patient per month
Clinical outcomes for patients receiving extended management
Provider efficiency and documentation quality metrics
Future Considerations and Opportunities
Expanding Clinical Complexity
As healthcare becomes increasingly complex, 98981 usage may grow:
Integration with multiple digital health platforms
Coordination with telehealth and other remote services
Management of patients with multiple chronic conditions
Advanced analytics requiring professional interpretation
Technology-Enhanced Efficiency
Future developments may improve 98981 clinical efficiency:
AI-powered data analysis reducing review time
Automated documentation systems
Predictive analytics identifying high-need patients
Streamlined communication platforms
Policy Evolution
Anticipated changes may affect 98981 implementation:
New time increment options (10–19 minute codes)
Expanded provider categories eligible for RTM billing
Enhanced documentation requirements
Integration with value-based care initiatives
CPT code 98981 enables comprehensive clinical oversight for complex RTM patients, ensuring that providers can deliver thorough, personalized remote care while maintaining appropriate compensation for extended professional time. When properly implemented, it supports both clinical excellence and sustainable revenue generation for sophisticated RTM programs.