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.