RTM Billing Modifiers and Place of Service Codes | Orva

Remote Therapeutic Monitoring

RTM Billing Modifiers and Place of Service Codes

Use the correct therapy modifiers and Place of Service codes to avoid denials for RTM. This guide covers GP, GO, GN, CQ, CO, when payers want 95, and common POS selections for non-face-to-face services and telemedicine.

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What you need to know

Therapy plan of careWhen RTM is furnished by therapists, services are therapy and usually need GP, GO, or GN.
AssistantsAppend CQ or CO when PTA or OTA involvement exceeds the de minimis threshold. Document who did what and when.
Interactive touchpointFor 98980 and 98981 you need a real-time, patient-facing interaction in the month. Some payers prefer modifier 95 to flag this.
Place of ServicePOS 11 Office is common for non-face-to-face services. Use POS 02 or 10 when required for telemedicine. Confirm payer rules.

Always confirm your MAC and commercial payer policies.

Therapy and telehealth modifiers

Therapy discipline

  • GP physical therapy
  • GO occupational therapy
  • GN speech-language pathology

Therapy assistants

  • CQ physical therapist assistant involvement above de minimis
  • CO occupational therapy assistant involvement above de minimis

Apply CQ or CO only when assistant involvement crosses the payer’s de minimis threshold.

Interactive touchpoint

  • 95 sometimes required by payers to indicate real-time, patient-facing communication

Messages alone are not interactive communication. A phone or video touchpoint satisfies the requirement when payer rules are met.

Place of Service codes

11 Office
Common for RTM when billed as non-face-to-face services by a clinic-based provider.
12 Home
Sometimes used when set-up or education occurs in the patient’s home and payer policy directs it.
02 Telehealth other than home
Use when the patient is outside the patient’s home during the real-time interaction.
10 Telehealth in the patient’s home
Use when the patient is in the patient’s home during the real-time interaction.

Verify POS requirements with your MAC and commercial payers. Some require 02 or 10 for telemedicine visits that satisfy the interactive requirement.

Practical examples

PT with assistant involvement

A PTA helps review RTM data and coach the patient above the de minimis threshold. Bill RTM with GP and CQ when requirements are met. Document the assistant’s work and minutes.

Monthly management via telemedicine

The therapist conducts a brief real-time video call to discuss progress. Use POS 10 when the patient is at home or POS 02 when not at home. Some payers want modifier 95 to indicate the interactive contact.

OT with no assistant involvement

OT manages RTM independently. Append GO. Do not append CO since the OTA did not exceed de minimis participation.

Speech-language pathology

SLP delivers RTM under a therapy plan of care. Append GN. Use 98980 or 98981 only when time and interactive communication requirements are satisfied.

Related RTM pages

RTM overview

What RTM is, who can bill, and how the codes fit together.

98975

Initial set-up and patient education. Report once per episode of care.

98977

Device supply and therapeutic data collection each 30 days.

98980

First 20 minutes of monthly management time with interactive communication.

98981

Each additional 20 minutes of management time in the same month after 98980.

See also the RTM 2026 updates.

Compliance note

Coding guidance here is educational and does not guarantee coverage or payment. Policies vary by payer and state. Always confirm current rules with your MAC and commercial payers.

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