Frequently Asked Questions About Remote Therapeutic Monitoring (RTM) and Orva

Remote Therapeutic Monitoring can be ordered and delivered by physicians and by a range of qualified non-physician providers. This includes physical therapists, occupational therapists, physician assistants, nurse practitioners, clinical nurse specialists, certified nurse midwives, and clinical psychologists. These providers must be operating within their scope of practice and must meet licensure and regulatory requirements where applicable. RTM codes are classified as general medicine codes, not evaluation and management codes, which is why physical and occupational therapists are eligible to bill for them. This distinction also makes RTM different from Remote Patient Monitoring, which is limited to providers who can bill evaluation and management services. The general medicine classification of RTM opens the door for a wider range of rehabilitation providers to participate in remote care programs and bill Medicare directly for their work.

To bill CPT code 98980, the provider must spend at least 20 minutes within a calendar month managing the patient’s remote therapeutic monitoring data. This includes interpreting the data, modifying the plan of care, and communicating with the patient. That communication must include at least one live, interactive conversation with the patient or their caregiver during that month. This can happen by phone, video, or another real-time communication method. CPT code 98981 is an add-on code and can be billed when an additional 20 minutes of management time are spent in the same calendar month. The same rules apply: time must be spent actively managing the patient and must include at least one live interaction during the period.

Yes. While RTM is structured similarly to Remote Patient Monitoring, its clinical use cases are more narrowly defined. The device supply code most commonly used in RTM, CPT code 98977, is limited to the monitoring of musculoskeletal conditions. That means the program must involve collecting data that informs treatment of the musculoskeletal system, such as joint pain, post-surgical recovery, mobility limitations, or other functional impairments. There are also separate RTM codes related to respiratory conditions, but they are rarely used in physical therapy or orthopedic settings. For most PT and orthopedic clinics, musculoskeletal RTM is the relevant focus.

CPT code 98975, which covers the setup and patient education portion of RTM, can be billed once per episode of care. An episode of care begins when the patient is onboarded to the RTM program and ends when the treatment goals outlined in the plan of care have been achieved or the patient is discharged. CPT code 98977, which covers the device supply and data transmission for musculoskeletal monitoring, can be billed once every 30 days as long as all requirements are met, including minimum data collection. CPT codes 98980 and 98981, which cover treatment management time, can be billed monthly as well. 98980 is billed once per month when at least 20 minutes of management time is reached and includes one live patient interaction. 98981 can be billed once more in that same month if an additional 20 minutes of qualifying time is reached.

To bill CPT code 98977, the patient’s device must collect and transmit at least 16 days of data within a 30-day period. These 16 days do not need to be consecutive, but they must fall within the same 30-day window in order to qualify. If the threshold is not met, the code cannot be billed for that period.

Yes. One of the unique aspects of RTM is that patient-reported data is allowed. CMS has confirmed that self-reported or manually entered data qualifies as long as the digital tool being used meets the Food and Drug Administration’s definition of a medical device. This means that patients can input their exercise completion, pain scores, or other non-physiologic information directly into an app or digital platform, and that data can be used to satisfy RTM requirements. The device used must still qualify as Software as a Medical Device (SaMD), but automatic transmission of physiologic data is not required the way it is in Remote Patient Monitoring. This flexibility is part of what makes RTM especially well suited to physical therapy and orthopedic care, where outcomes are driven by behavior and function, not just biometrics.

RTM billing requires clear documentation of each billed activity. For 98975, clinics should record the date of setup, the specific patient education provided, and confirmation that the patient was given access to the RTM platform or device. For 98977, the clinic must be able to show that the patient engaged with the tool or application on at least 16 separate days during the billing period. This data is typically pulled directly from the software.

For codes 98980 and 98981, clinicians need to document the amount of time spent reviewing data, making clinical decisions, modifying the plan of care, and communicating with the patient. Notes should include the total time, the nature of any plan changes, and the content and timing of any interactive communication with the patient. Orva tracks all of this automatically in the background, but clinicians should still review and sign off on the reports to ensure accuracy and compliance.

No. Unlike Remote Patient Monitoring, which requires a physical device to collect and transmit physiologic data automatically, RTM allows for the use of software-only tools. The key requirement is that the software qualifies as a medical device under the FDA’s definition. In most PT and orthopedic contexts, this includes mobile applications classified as Software as a Medical Device (SaMD) that track exercises, pain scores, range of motion, or other functional outcomes. These tools do not need to measure vital signs or include wearable hardware. They do need to be capable of securely capturing and storing patient data and transmitting it to the provider in a reliable format.

An episode of care begins when the patient is first set up with the RTM service and continues until the treatment goals outlined in the plan of care are met or until the patient is discharged. If a patient completes their initial course of care and later returns with a new issue or diagnosis that warrants a new plan, a new episode of care may begin and CPT code 98975 can be billed again. The episode must be clinically distinct and not simply a continuation of the previous treatment plan. This distinction helps prevent duplication and ensures compliance with Medicare’s rules for time-based billing.

No. Physical therapists and occupational therapists can independently bill RTM under their own National Provider Identifier (NPI) as long as they are practicing within their scope and state guidelines. There is no requirement that a physician co-sign RTM reports or oversee the service. However, the therapist must maintain accurate and complete documentation, and in certain settings—such as hospital-based outpatient departments—additional supervisory rules may apply.

Only one provider can bill RTM codes for a patient during any given 30-day period. This is true even if multiple types of services are being delivered. For example, if a physical therapist and an occupational therapist are both involved in the patient’s care, only one of them can bill for the RTM services during that window. The same is true across specialties. If a primary care physician or another provider is also enrolled in an RTM program for that patient, coordination is required to avoid duplication. In practice, this means the provider most directly managing the patient’s functional recovery should take ownership of the RTM episode and billing.

Medicare was the first to define and reimburse for Remote Therapeutic Monitoring, but many commercial insurers have followed suit. That said, coverage varies by plan and by state. Some payers mirror Medicare’s rules exactly, while others modify or limit eligibility based on their own internal guidelines. For example, some plans only reimburse when the referring provider is a physician, even though Medicare allows physical therapists to bill directly. Others may deny claims initially and require appeal or additional documentation. Orva works closely with partner clinics to understand local patterns and helps identify which payers are actively reimbursing. We also operate with a simple principle: you will never be charged for patients whose RTM claims are denied by a commercial payer. This allows clinics to try RTM with confidence, even in mixed-payer environments.

The place of service (POS) code generally reflects where the provider is located when the service is rendered. For outpatient clinics, this is usually POS 11. In some cases, such as hospital-based settings or home health, different POS codes may apply. Modifier 95 is not typically required for RTM, because RTM is not considered a telehealth service, but some private payers may request it anyway. Medicare has clarified that RTM is distinct from telehealth and is not subject to the same restrictions. However, clinics should always check the most current billing guidance for their region and payer mix. Orva provides prebuilt RTM reports formatted to match what Medicare and most commercial payers expect, but we also support customization when local requirements differ.

Remote Therapeutic Monitoring and Remote Patient Monitoring are often compared, but they serve different purposes and have different rules. RPM is built around physiologic data such as blood pressure, glucose levels, or weight, and it requires a device that automatically records and transmits this data. RPM also falls under evaluation and management services, which means only physicians and certain advanced practice providers can bill for it.

RTM, on the other hand, focuses on non-physiologic data related to therapeutic response. This includes things like home exercise adherence, pain levels, range of motion, and functional improvement. RTM allows patients to self-report this data using a software application, as long as that software qualifies as a medical device. RTM is classified as a general medicine service, which opens it up to physical therapists and occupational therapists as direct billers. This distinction makes RTM much more accessible for musculoskeletal care and better aligned with the type of monitoring that actually drives recovery in PT and orthopedic settings.

Yes. Orva is built from the ground up to meet all Medicare and commercial payer requirements for Remote Therapeutic Monitoring. The Orva platform is classified as Software as a Medical Device (SaMD), and it automatically tracks all required data, including exercise adherence, patient-reported outcomes, and daily engagement. Orva also logs clinician activity in the background, so whenever you review patient progress, adjust a plan of care, or send messages that involve clinical decision-making, the time is recorded and available in a structured report. Each report is formatted to match the documentation expectations of Medicare and most private payers, and can be exported or integrated into your existing billing process with no extra work.

Orva does not require direct integration with your EMR in order to bill for RTM. Most clinics use Orva alongside their documentation platform, and the billing handoff is quick and seamless. If integration is important to your workflow, our team is happy to explore what’s possible based on your EMR.

Orva automates nearly all aspects of RTM compliance. The platform ensures that usage thresholds are being met before generating reports. It alerts providers when patients are not on track to qualify so that engagement strategies can be adjusted. It time-stamps all clinician interactions and patient engagement. Reports are locked and archived to prevent retroactive edits, and all audit trails are fully transparent. In the event of a payer audit, every required detail is already documented and available. For clinics that want an extra layer of assurance, Orva’s support team can also review reports on a monthly basis to flag any potential issues before claims are submitted.

RTM compliance is about more than just checking boxes. It’s about proving that meaningful care is being delivered between visits. Orva is designed to help clinics do exactly that—without adding extra paperwork or friction for the provider.

Patients are typically onboarded to Remote Therapeutic Monitoring during their initial evaluation or at the start of a new episode of care. In the Orva platform, setup takes just a few minutes. Clinicians select the condition-specific program, adjust the exercises or frequency as needed, and enable RTM tracking with a single toggle. Patients receive an invite by text or email and can begin using the app immediately. For clinics using Orva, all onboarding steps—including education, consent, and documentation—are captured and recorded automatically. This makes it easy to support compliance without adding time to the visit. Once the program is assigned, Orva begins tracking engagement in the background, and clinicians are notified if patients fall off track.

Once the goals of care are met or the patient is discharged for another reason, the RTM episode is considered complete. Orva automatically ends the episode when no new activity is logged for a defined period, or when the clinician manually marks the program as complete. No further RTM codes can be billed after discharge, and billing should stop immediately if the patient is no longer being actively monitored. If the patient later returns with a new condition or a new plan of care, a new episode can be created and CPT 98975 can be billed again, assuming all other requirements are met. Keeping these episodes distinct and well-documented is important for compliance and audit readiness.

The most frequent issues come down to thresholds, timing, and documentation. One common mistake is billing the device code (98977) without meeting the full 16-day requirement. If a patient misses too many days, or if the reporting period is cut short due to discharge or cancellation, the code cannot be billed. Another issue is failing to reach the full 20 minutes of treatment management time needed to bill 98980. Clinics sometimes misinterpret communication as automatically counting toward this time, but only medically necessary management tasks—like reviewing trends, adjusting plans, or discussing progress—can be included. It’s also essential that at least one live, real-time interaction with the patient or caregiver occurs each month in order for 98980 to be valid.

Orva helps mitigate these risks by monitoring thresholds in real time and alerting clinicians when patients are at risk of not qualifying. The platform also time-tracks management activities automatically, so clinicians don’t need to manually record minutes or justify their time after the fact.

For most outpatient orthopedic and physical therapy clinics, RTM provides a meaningful new revenue stream that rewards the care teams for work they are already doing between visits. Each qualifying patient can generate up to $390 or more over a typical three-month episode. That reimbursement comes in addition to visit-based revenue and does not require new hires or equipment. Most practices start seeing financial return within the first month. The key is consistent execution and good patient engagement, both of which are built into the Orva platform. Because Orva only charges for patients who qualify and generate claims, clinics are never at risk of spending more than they earn. This makes RTM both low-risk and high-upside when implemented correctly.

Very little. Orva clinics are typically live in under an hour. We recommend identifying one point person in your clinic to lead the initial rollout, but beyond that, clinicians can begin assigning programs with just a few minutes of training. The patient experience is just as simple. The app guides users step by step, with reminders and feedback built in. No downloads are required, and technical support is available for both patients and staff.

Our team provides onboarding, staff training, documentation support, and billing guidance. Clinics can also test the platform risk-free by enrolling a few patients before rolling it out more broadly.

RTM is entirely optional on a per-patient basis. If you assign a home program in Orva but don’t want to enable RTM for a given patient, you can simply toggle the RTM feature off during setup. The patient still receives the same experience, and you still have access to all of their data. The only difference is that Orva will not generate monthly reports or initiate billing for those patients. This gives clinics full flexibility to choose when and how to use RTM based on individual payer status, clinical appropriateness, or patient preference.

Clinics participating in Remote Therapeutic Monitoring should expect the possibility of being audited just like they would be for any other reimbursable service. Audits may be conducted by Medicare Administrative Contractors, private payers, or third-party auditors contracted by CMS. The most important thing is to ensure that all billed services meet the full requirements of each CPT code and that documentation clearly reflects that.

For RTM, this means having evidence that the patient was set up properly, that at least 16 days of engagement occurred if billing the device code, that at least 20 minutes of management was provided when billing the treatment codes, and that interactive communication took place. It also means making sure that the same codes were not billed by other providers for the same patient during the same period.

Orva provides detailed audit-ready reports for every patient and automatically prevents billing reports from being generated if a patient is not on track to qualify. Reports are locked once finalized and contain time stamps for all key events, including clinician review, patient use, plan changes, and communication. This ensures clinics have everything they need in the event of a payer audit, without needing to dig through notes or build custom documentation after the fact.

Software as a Medical Device is a category defined by the Food and Drug Administration to describe software products that meet the definition of a medical device but do not require any accompanying hardware. This includes many mobile health apps, especially those used for treatment, diagnosis, prevention, or monitoring. For a digital platform to qualify as the “device” in Remote Therapeutic Monitoring, it must meet this definition. Not every health or fitness app qualifies.

Orva is classified as Software as a Medical Device because it is designed for clinical use and meets the necessary standards for security, reliability, and intended use. It tracks treatment adherence, functional progress, and patient-reported outcomes in a structured way that can be used for billing and clinical decision-making. This classification is what allows Orva to meet Medicare’s requirements for CPT code 98977 and helps ensure that partner clinics are operating within the rules.

We have patients as young as 15 and as old as 78 actively using the platform. In fact, the Medicare-age population is slightly more adherent than average. With the right design and support, age or tech comfort rarely becomes a barrier.

The Centers for Medicare and Medicaid Services recently proposed new RTM codes that would allow billing for shorter engagement periods and fewer minutes of treatment management time. These proposed changes are set to take effect in 2026 and would allow clinics to receive partial reimbursement for patients who use the program for only part of the month or who require less clinical management. This reflects a growing recognition that care is not always one-size-fits-all.

In addition to new codes, CMS has also expressed interest in supporting software-based care delivery models more broadly. This could mean future rule changes that expand the types of conditions that qualify for RTM or increase reimbursement for digital health services. Commercial payers are also continuing to refine their RTM policies, and many are starting to follow Medicare’s lead.

The bottom line is that RTM is becoming more central to outpatient care, not less. Clinics that build this capability into their model now will be better positioned to succeed as reimbursement evolves. Orva is designed to stay ahead of these changes, with ongoing updates and policy monitoring built into the platform and the team.