Georgia Medicare Remote Therapeutic Monitoring RTM 2026

By Brevy Care Team

Medicare Remote Therapeutic Monitoring — RTM — fills the gaps that Remote Physiologic Monitoring (RPM) leaves behind. Where RPM covers physiologic data automatically transmitted from FDA medical devices (weight, blood pressure, pulse oximetry, heart rate, glucose), RTM covers therapeutic data — musculoskeletal system status, respiratory system status, and cognitive behavioral therapy monitoring — and uniquely allows patient-reported (self-entered) data, not only auto-transmitted device data. Beneath the technical distinction sits a larger one: RTM brings physical therapists, occupational therapists, speech-language pathologists, and clinical psychologists into the remote monitoring payment framework. Those clinicians could not historically bill RPM treatment management codes. RTM lets them bill treatment management of remotely monitored therapeutic data within their scope of practice.

For Georgia Medicare beneficiaries, RTM matters because so much of post-acute and chronic therapy work is now done outside the clinic. After a total knee replacement, the meaningful work happens at home through daily range-of-motion exercises. After a COPD exacerbation, the meaningful work happens at home through inhaler use tracking and symptom monitoring. After a depression diagnosis, the meaningful work happens at home through CBT homework and mood tracking. RTM creates a payment pathway for the therapist or behavioral health clinician to monitor that work between visits, intervene when adherence drops or symptoms worsen, and document the connection between data trends and outcomes.

This guide explains how RTM works under Medicare, what each CPT code covers, the 16-day measurement requirement that gates device supply billing, the 20-minute interactive communication requirement that gates treatment management billing, the patient-reported data allowance that distinguishes RTM from RPM, the qualified professional scope, cost-sharing, coordination with other Medicare care-management services, and the Georgia delivery landscape across major health systems, outpatient therapy networks, pulmonary rehabilitation programs, and behavioral health practices.

Key takeaways

• RTM is a separate code family from RPM. RPM uses CPT 99453, 99454, 99457, 99458 for physiologic data. RTM uses CPT 98975, 98976, 98977, 98978, 98980, 98981 for therapeutic data.
• RTM became effective January 1, 2022 under the CY 2022 Medicare Physician Fee Schedule final rule.
• Patient-reported data is allowed under RTM — a defining distinction from RPM, which requires automatic device transmission.
• Three device-supply codes cover the three monitoring domains: 98976 respiratory, 98977 musculoskeletal, 98978 cognitive behavioral therapy.
• CPT 98975 covers initial device setup and patient education, reported once per episode of care.
• CPT 98980 covers the first 20 minutes per calendar month of treatment management with interactive communication.
• CPT 98981 covers each additional 20 minutes as an add-on to 98980.
• Device-supply codes (98976, 98977) require at least 16 days of measurement within a 30-day period.
• Qualified professionals include therapists and clinical psychologists, not only physicians and APPs.
• Cost-sharing is standard Part B — deductible plus 20% coinsurance, unless covered by QMB, Medigap, or Medicare Advantage benefits.

Framework: how RTM works under Medicare

RTM rests on a parallel architecture to RPM with three meaningful differences. First, it covers non-physiologic therapeutic data — the data your therapist or behavioral health clinician would use to know whether you're doing your prescribed home program and whether it's working. Second, it allows patient-reported data, not only automatic device uploads. Third, it expands the qualified professional scope to include therapists and clinical psychologists.

The core architecture has three parts: initial setup billed once, device supply billed monthly tied to a 16-day measurement floor, and treatment management billed in 20-minute increments per calendar month.

Initial setup — CPT 98975

CPT 98975 covers the initial setup of the remote monitoring system and patient education on its use. It is billed once per episode of care — not monthly. The work includes provisioning the device, training the patient on how to use it, verifying connectivity, and documenting consent. The Medicare-approved amount is modest because the work is bounded; the operational complexity lives in the staff time required to actually get a beneficiary using a device successfully.

For musculoskeletal RTM, the device is often a sensor or app paired with a home exercise program. For respiratory RTM, the device is often a spirometer, peak flow meter, or smart inhaler. For cognitive behavioral therapy RTM, the device is often an app or platform supporting mood tracking, CBT homework, and behavioral data.

Device supply — CPT 98976 (respiratory), CPT 98977 (musculoskeletal), CPT 98978 (CBT)

Three separate device-supply codes correspond to the three RTM monitoring domains.

CPT 98976 covers device supply for monitoring the respiratory system. The Medicare-approved amount is paid per 30-day period when at least 16 days of measurements are recorded within that period. The 16-day requirement is identical in form to the RPM 16-day requirement for CPT 99454.

CPT 98977 covers device supply for monitoring the musculoskeletal system. Same 30-day cycle, same 16-day measurement requirement. Most outpatient therapy RTM falls under 98977 — post-surgical rehab, chronic musculoskeletal pain, mobility limitations, and similar therapeutic monitoring.

CPT 98978 covers device supply for monitoring cognitive behavioral therapy. The structure parallels the others but applies to behavioral health monitoring under CBT principles.

Across all three device codes, the data may be patient-reported. This is the defining structural difference from RPM. RPM device data must be automatically transmitted from an FDA medical device — patient-entered data does not qualify. RTM data may be patient-reported because the therapeutic work itself often requires patient input (pain scale, symptom diary, exercise completion, mood rating).

Treatment management — CPT 98980 and CPT 98981

CPT 98980 covers the first 20 minutes of RTM treatment management services per calendar month. It requires interactive communication with the patient or caregiver during that month. The interactive communication can be synchronous audio-video, audio-only telephone, or other real-time interactive modality. Time counts treatment management work including data review, intervention planning, plan-of-treatment updates, communication with the patient or caregiver, and care coordination.

CPT 98981 covers each additional 20 minutes within the same calendar month as an add-on to 98980. It cannot be billed without 98980. Each additional 20 minutes can be reported separately, supporting recognition of more intensive monitoring episodes.

The 20-minute floor for 98980 mirrors the RPM 20-minute floor for CPT 99457. The interactive communication requirement is identical in concept.

Qualified professionals — the RTM scope expansion

RTM's most consequential structural feature is that treatment management codes (CPT 98980 and 98981) are billable by professionals beyond physicians, NPs, PAs, and CNSs. Physical therapists, occupational therapists, speech-language pathologists, and clinical psychologists can bill RTM treatment management when furnishing within their scope of practice and consistent with their plan of treatment.

This is a meaningful access expansion. Therapists are often the clinicians most involved with the underlying therapeutic monitoring work — they design the home exercise program, they teach the patient how to use the device, they interpret the data, and they intervene when adherence drops. RTM lets the therapist bill for that time directly rather than routing it through a physician's incident-to arrangement.

Auxiliary personnel furnishing portions of treatment management work under incident-to to a physician remain a parallel pathway. The expansion is additive, not exclusive.

Three monitoring domains

Musculoskeletal monitoring (CPT 98977)

The musculoskeletal RTM domain covers any therapeutic monitoring of the musculoskeletal system — joint range of motion, exercise adherence, pain levels, mobility, strength. The most common Georgia use cases are post-orthopedic-surgery rehabilitation (post-TKA, post-THA, post-rotator-cuff, post-spine), chronic musculoskeletal pain management (chronic low back pain, neck pain, arthritis), and mobility-limitation monitoring.

Devices in this domain range from simple — a sensor-equipped exercise device, a wearable inertial measurement unit, a smartphone app capturing exercise videos — to integrated platforms tracking exercise completion against a prescribed home program.

Patient-reported data fits this domain naturally. Pain scales, perceived exertion, exercise completion checklists, and mobility self-reports are all therapeutic data.

Respiratory monitoring (CPT 98976)

The respiratory RTM domain covers therapeutic monitoring of the respiratory system — symptom tracking, inhaler use, peak flow trends, breathlessness, sputum changes. The most common Georgia use cases are COPD management between pulmonary rehab episodes, asthma management, post-pneumonia monitoring, and chronic respiratory disease management.

Devices include smart inhalers tracking actuation timing, peak flow meters with cellular or Bluetooth connectivity, spirometers, and symptom-tracking apps. Patient-reported data — symptom severity, exacerbation flags, inhaler use confirmation — is core to this domain.

Note the relationship with RPM pulse oximetry monitoring: pulse oximetry is physiologic data (oxygen saturation) that fits RPM under CPT 99454 because it is an automatic device measurement. Respiratory symptom and inhaler-use monitoring fits RTM under CPT 98976 because it includes patient-reported components. A patient may receive RPM oximetry and RTM respiratory symptom monitoring simultaneously if clinically warranted, but the device-supply codes cannot be billed for the same monitoring episode.

Cognitive behavioral therapy monitoring (CPT 98978)

The CBT RTM domain covers therapeutic monitoring of behavioral health under cognitive behavioral therapy principles — mood tracking, CBT homework completion, behavioral activation activities, anxiety levels, sleep tracking. Common Georgia use cases include depression management, anxiety management, sleep disorder management, and behavioral interventions for chronic pain.

Devices include behavioral health platforms supporting CBT-based protocols, mood-tracking apps, and digital therapeutics with FDA clearance.

The relationship with Behavioral Health Integration (BHI) services is one of complementarity. BHI under CPT 99484 and the Collaborative Care Model codes 99492-99494 covers psychiatric consultation and care management for behavioral health conditions integrated in primary care. RTM under 98978 covers device-supported monitoring of CBT work. The two can coexist when clinically warranted.

RTM vs RPM: the defining distinction

The cleanest way to think about RTM and RPM is that they are parallel architectures with three structural differences:

1. Data type. RPM covers physiologic data. RTM covers therapeutic data.
2. Patient-reported allowance. RPM requires automatic device transmission. RTM allows patient-reported data.
3. Qualified professional scope. RPM treatment management codes are billable by physicians and APPs (with auxiliary personnel under general supervision). RTM treatment management codes are additionally billable by physical therapists, occupational therapists, speech-language pathologists, and clinical psychologists.

Many other features are parallel:

• 16-day measurement requirement for device-supply codes (RPM 99454, RTM 98976/98977).
• 20-minute interactive communication requirement for treatment management first 20 minutes (RPM 99457, RTM 98980).
• Additional 20-minute add-on for extended management (RPM 99458, RTM 98981).
• Standard Part B cost-sharing — deductible plus 20% coinsurance.
• Patient consent requirement at initiation.
• Acute and chronic condition eligibility.
• Single practitioner per month rule for the same monitoring episode.

A single beneficiary can receive both RPM and RTM in the same calendar month for different monitoring episodes — for example, RPM for heart failure weight and blood pressure monitoring while receiving RTM for post-knee rehab range-of-motion monitoring. The two codes cannot be billed for the same monitoring episode.

The 16-day measurement requirement

CPT 98976 and 98977 require at least 16 days of measurements within a 30-day period to support billing. If fewer than 16 days of measurements are recorded, the device-supply code cannot be billed for that 30-day cycle.

CPT 98978 (CBT monitoring) follows the same 16-day structure in practice; programs treat it as the operative threshold for the device-supply billing under that code.

Days with no data do not count toward the 16. Days with at least one valid measurement count. The work of getting beneficiaries to consistent device use — patient education, technical support, motivation, troubleshooting — is the work that converts CPT 98975 setup into reliable monthly CPT 98976/98977 billing.

The 20-minute interactive communication requirement

CPT 98980 requires at least 20 minutes of RTM treatment management services within the calendar month, including at least one episode of interactive communication with the patient or caregiver. The interactive communication can be:

• Synchronous audio-video (telehealth visit)
• Audio-only telephone
• Other real-time interactive modality

Time counts the treatment management work — data review, intervention planning, plan-of-treatment updates, communication with the patient or caregiver, and care coordination. The interactive communication itself can be brief; the bulk of the time may be data review and care coordination outside of patient interaction.

CPT 98981 covers each additional 20 minutes within the same calendar month. Each additional 20-minute increment can be reported separately, supporting recognition of more intensive monitoring episodes.

FDA medical device requirement

RTM device-supply codes require the device to meet the FDA definition of a medical device under section 201(h) of the Federal Food, Drug, and Cosmetic Act. Cleared/approved status under 510(k), De Novo, or PMA pathway typically qualifies. General-purpose consumer apps without FDA clearance generally do not qualify even if they capture useful data.

Within the FDA-cleared device universe, however, RTM allows the data to be patient-reported. The device must be an FDA medical device; the data captured by the device may originate as patient input rather than purely automatic measurement. This is the structural feature that opens RTM to apps and platforms supporting CBT homework, exercise completion, and symptom diaries that would not qualify under RPM.

Cost-sharing structure

RTM is subject to standard Part B cost-sharing — the Part B annual deductible plus 20% coinsurance on each RTM code billed.

Approximate Medicare-approved amounts (CY 2026, illustrative):

• CPT 98975 (initial setup): ~$19, patient 20% ~$3.80
• CPT 98976 (respiratory device supply): ~$48 per 30 days, patient 20% ~$9.60
• CPT 98977 (musculoskeletal device supply): ~$48 per 30 days, patient 20% ~$9.60
• CPT 98978 (CBT device supply): ~$48 per 30 days, patient 20% ~$9.60
• CPT 98980 (first 20 min management): ~$48 per month, patient 20% ~$9.60
• CPT 98981 (each additional 20 min): ~$39 per 20-min increment, patient 20% ~$7.80

Total monthly RTM cost-sharing typically ~$20–30 for setup-month, ~$15–25 for ongoing months.

Coverage that reduces or eliminates cost-sharing:

• QMB (Qualified Medicare Beneficiary): cost-sharing covered by Georgia Medicaid
• Medigap: per plan benefits
• Medicare Advantage: per plan benefits, often $0 or low copay

Coordination with other Medicare services

RTM coordinates with the rest of the Medicare care-management architecture rather than competing with it.

RTM + RPM

Same calendar month billing permitted for different monitoring episodes. RTM and RPM can be combined when a patient has both a physiologic monitoring need (RPM territory) and a therapeutic monitoring need (RTM territory). They cannot be billed for the same monitoring episode.

RTM + CCM (CPT 99490)

Same calendar month billing permitted. CCM covers chronic disease care coordination; RTM covers device-based therapeutic monitoring of specific conditions. Time tracking distinct.

RTM + PCM (CPT 99424-99427)

Same calendar month billing permitted. PCM covers single-condition specialist management; RTM covers device-based therapeutic monitoring of that or another condition.

RTM + BHI (CPT 99484, 99492-99494)

Same calendar month billing permitted. BHI covers behavioral health integration in primary care; RTM under 98978 covers CBT-specific device monitoring. The two can coexist with distinct documentation.

RTM + TCM (CPT 99495/99496)

TCM covers the 30-day post-discharge transition. RTM provides ongoing therapeutic monitoring through that transition and beyond. Common post-surgical or post-rehabilitation use case.

RTM + outpatient therapy (PT/OT/SLP) plan of treatment

RTM is delivered under the standard outpatient therapy plan-of-treatment framework when furnished by therapists. The plan of treatment governs the therapy services; RTM is one component of that plan when the therapist incorporates device-based monitoring.

RTM + E/M visits

Separately billable. Office visits and telehealth visits coordinate with RTM data but follow standard E/M documentation requirements.

Patient consent

Patient consent is required at RTM initiation. Consent may be verbal or written, documented in the medical record, and covers:

• The RTM service and its purpose
• The expected cost-sharing
• The patient's ability to discontinue at any time
• The data flow to the practice and how it will be used

Consent supports patient understanding of cost and process and is a standard Medicare care-management requirement consistent with CCM, PCM, BHI, and RPM consent.

Single practitioner per month rule

Only one practitioner may bill RTM services per patient per 30-day period for the same monitoring episode. The rule prevents duplicate billing across multiple practitioners. The patient retains choice of RTM service practitioner; care coordination among the patient's clinicians supports designation of the responsible RTM practitioner.

Worked examples

1. Fulton 70 — post-TKA musculoskeletal RTM at Emory

A 70-year-old Fulton County beneficiary is six weeks post-total-knee-arthroplasty receiving outpatient physical therapy at an Emory clinic. The therapist enrolls the beneficiary in a musculoskeletal RTM program using a sensor-equipped home exercise device that tracks range-of-motion exercises and pain ratings.

Billing for the first month:

• CPT 98975 — initial setup and patient education on the device (~$19)
• CPT 98977 — device supply, 22 days of measurements recorded (>16-day floor) (~$48)
• CPT 98980 — 22 minutes treatment management including interactive phone check-in (~$48)

Total Medicare-approved ~$115. Beneficiary 20% coinsurance ~$23.

2. DeKalb 68 — COPD respiratory RTM at Piedmont

A 68-year-old DeKalb County beneficiary with moderate COPD completes pulmonary rehab and transitions to respiratory RTM at a Piedmont program. The program uses a smart inhaler tracking actuation timing plus a symptom-tracking app capturing patient-reported daily symptom severity and inhaler use.

Billing for ongoing months:

• CPT 98976 — respiratory device supply, 19 days of measurements (>16-day floor) (~$48)
• CPT 98980 — 21 minutes treatment management including video check-in (~$48)

Beneficiary 20% coinsurance ~$19/month.

3. Cobb 72 — chronic low back pain musculoskeletal RTM at Wellstar

A 72-year-old Cobb County beneficiary with chronic low back pain enrolls in a musculoskeletal RTM program at a Wellstar outpatient therapy clinic. The program uses an app with daily home exercise tracking, pain scale ratings, and weekly therapist video check-ins.

Billing for a month with intensive management:

• CPT 98977 — device supply, 27 days of measurements (~$48)
• CPT 98980 — first 20 minutes treatment management (~$48)
• CPT 98981 — additional 22 minutes treatment management (~$39)

Total 42 minutes of treatment management. Beneficiary 20% coinsurance ~$27.

4. Worth County 75 — rural shoulder rehab telehealth RTM at Phoebe Putney

A 75-year-old Worth County beneficiary is recovering from rotator cuff repair. The orthopedic surgeon is in Albany; the beneficiary lives 35 miles south. Phoebe Putney's telehealth PT program enrolls the beneficiary in a musculoskeletal RTM program with telehealth check-ins and a home exercise app.

Billing for the first month:

• CPT 98975 — initial setup with telehealth education session (~$19)
• CPT 98977 — device supply, 21 days of measurements (~$48)
• CPT 98980 — 21 minutes treatment management with telehealth video check-in (~$48)

Beneficiary 20% coinsurance ~$23.

5. Bibb 65 — CBT-monitored depression RTM at Atrium Health Navicent

A 65-year-old Bibb County beneficiary with moderate depression begins CBT under a clinical psychologist at Atrium Health Navicent. The psychologist enrolls the beneficiary in a CBT RTM program using a digital therapeutic platform supporting mood tracking and CBT homework.

Billing for ongoing months:

• CPT 98978 — CBT device supply (~$48)
• CPT 98980 — 22 minutes treatment management including video CBT session check-in (~$48)

Beneficiary 20% coinsurance ~$19/month.

6. Hall 74 — combined RPM + RTM at Northeast Georgia

A 74-year-old Hall County beneficiary has both heart failure and recent total knee arthroplasty rehabilitation. Northeast Georgia Health System enrolls the beneficiary in RPM for heart failure (weight and blood pressure monitoring) and RTM for musculoskeletal rehabilitation (range-of-motion and exercise tracking).

Billing for the month:

• RPM: CPT 99454 + CPT 99457 (heart failure monitoring)
• RTM: CPT 98977 + CPT 98980 (knee rehab monitoring)

The two monitoring episodes are clinically distinct, and the codes coexist for the same patient in the same calendar month. Total beneficiary 20% coinsurance ~$38–45 depending on exact reimbursement.

14 best practices for Georgia RTM

1. Match the monitoring domain to the patient's primary therapeutic need. Choose 98976 for respiratory, 98977 for musculoskeletal, 98978 for CBT. A patient with multiple needs may receive sequential or coordinated RTM but only one monitoring episode per code at a time.

2. Use the qualified professional scope expansion deliberately. Therapists and clinical psychologists can bill RTM treatment management directly; design workflows that recognize and leverage this.

3. Educate the patient thoroughly at CPT 98975 setup. Sustained 16-day measurement adherence depends on the patient understanding the device, its purpose, and how to use it.

4. Verify 16-day measurement thresholds before billing 98976/98977/98978. Audit-defensible measurement counts protect billing integrity.

5. Document interactive communication content for CPT 98980. Specify mode (audio-video, audio-only, in-person), date/time, duration, and substantive content.

6. Distinguish RTM time from CCM/PCM/BHI/RPM time when same calendar month. Time tracked for one service cannot count toward another.

7. Use patient-reported data appropriately. RTM's patient-reported data allowance is a feature; structure data capture to support both adherence and meaningful clinical interpretation.

8. Coordinate with the plan of treatment when therapist-furnished. RTM integrates into the standard outpatient therapy plan-of-treatment framework.

9. Consider RPM + RTM combinations when clinically warranted. A single patient may have both physiologic and therapeutic monitoring needs; the codes can coexist for distinct monitoring episodes.

10. Plan for the single practitioner per month rule. Designate the responsible RTM practitioner and coordinate among the patient's clinicians.

11. Use telehealth interactive communication for rural access. Audio-video or audio-only telephone interactive communication supports rural Georgia beneficiaries.

12. Verify FDA medical device status of the platform. Confirm 510(k), De Novo, or PMA clearance documentation.

13. Build adherence support workflows. Patient education, technical support, motivation, and troubleshooting convert CPT 98975 setup into reliable monthly billing.

14. Document cost-sharing transparently at enrollment. Beneficiaries should understand the deductible, coinsurance, and any QMB/Medigap/Medicare Advantage coverage that applies.

14 common issues and how to handle them

1. Less than 16 days of measurement. Cannot bill device supply code for that 30-day cycle. Reinforce patient education; investigate device or connectivity issues.

2. Inadequate documentation of interactive communication. Without documented interactive communication, CPT 98980 cannot be supported. Document mode, date, duration, and substantive content.

3. Confusion between RTM and RPM. Many programs and beneficiaries conflate the two. The cleanest distinction is data type — physiologic (RPM) vs therapeutic (RTM) — and patient-reported allowance.

4. Billing both RTM and RPM for the same monitoring episode. Not permitted. Choose the appropriate code family for the monitoring episode.

5. Qualified professional scope confusion. Therapists and clinical psychologists can bill RTM treatment management; physicians and APPs can also bill it. Confirm the billing professional's scope of practice and plan-of-treatment role.

6. Time-tracking overlap with CCM/PCM/BHI. Time tracked for RTM cannot also count toward CCM, PCM, or BHI within the same calendar month. Maintain distinct time logs.

7. Patient device adherence dropping below 16-day threshold over time. Build periodic adherence checks and re-education into program workflows.

8. Single practitioner per month rule violations. Multiple practitioners attempting to bill RTM for the same patient and monitoring episode in the same month. Coordinate among the patient's clinicians.

9. FDA medical device status not verified. Some platforms in market lack FDA clearance. Verify status before enrollment.

10. Patient consent not documented at initiation. Verbal or written consent must be documented in the medical record at the start of the RTM service.

11. Confusion between RTM CBT monitoring and BHI services. RTM 98978 covers device-supported CBT monitoring; BHI 99484/99492-99494 covers psychiatric consultation and care management. Both can coexist with distinct documentation.

12. Cost-sharing surprise at billing. Beneficiaries may not realize the 20% coinsurance applies. Disclose cost-sharing at enrollment.

13. Audio-only telephone interactive communication not documented as such. When using audio-only telephone for interactive communication, document the mode explicitly.

14. Plan-of-treatment integration absent when therapist-furnished. RTM furnished by a therapist should integrate into the standard outpatient therapy plan-of-treatment framework with appropriate documentation.

Georgia RTM delivery infrastructure

Major Georgia health system RTM programs

• Emory Healthcare — Outpatient therapy musculoskeletal RTM, pulmonary rehab respiratory RTM, behavioral health CBT RTM. Strong telehealth integration.
• Wellstar Health System — Wellstar at Home and outpatient therapy musculoskeletal RTM. Pulmonary rehab respiratory RTM at multiple sites.
• Piedmont Healthcare — Piedmont @ Home and outpatient therapy RTM across musculoskeletal, respiratory, and behavioral health domains.
• Northside Hospital — Orthopedic RTM and musculoskeletal therapy RTM.
• Augusta University Health — Academic medical center RTM programs across multiple domains.
• Atrium Health Navicent (Central Georgia) — Central Georgia RTM including musculoskeletal and behavioral health.
• Memorial Health (Savannah) — Coastal Georgia RTM including pulmonary rehab respiratory monitoring.
• Phoebe Putney Health System (Southwest Georgia) — Telehealth-enabled rural RTM across musculoskeletal and respiratory domains.
• Northeast Georgia Health System — RTM integrated with broader care management.
• Atlanta VA Health Care System — VA telehealth RTM (separate authority).

Major Georgia outpatient therapy networks

• BenchMark Physical Therapy (statewide)
• Drayer Physical Therapy Institute (statewide)
• Athletico Physical Therapy
• Hospital-system outpatient therapy clinics

Major Georgia pulmonary rehabilitation programs

• Emory Pulmonary Rehab
• Wellstar Pulmonary Rehab
• Piedmont Pulmonary Rehab
• Augusta University Pulmonary Rehab
• Atrium Health Navicent Pulmonary Rehab
• Phoebe Putney Pulmonary Rehab

Major Georgia behavioral health systems delivering CBT RTM

• Emory Behavioral Health
• Skyland Trail
• Behavioral Health Link
• Local independent psychology practices delivering CBT under Medicare

Rural Georgia considerations

• Telehealth interactive communication for both audio-video and audio-only supports rural Georgia beneficiaries
• Cellular-enabled devices preferred over WiFi-dependent devices in counties with broadband gaps
• Georgia Telehealth Resource Center supports rural telehealth deployment
• Critical access hospitals and rural health clinics increasingly delivering RTM through partnerships

Frequently asked questions

1. What is Remote Therapeutic Monitoring (RTM)?

RTM is a Medicare service paying for the work of remotely monitoring therapeutic data — musculoskeletal, respiratory, or cognitive behavioral therapy data — between in-person or telehealth visits. It became effective January 1, 2022 under the CY 2022 Medicare Physician Fee Schedule final rule.

2. How is RTM different from Remote Physiologic Monitoring (RPM)?

RTM covers therapeutic (non-physiologic) data and uniquely allows patient-reported data. RPM covers physiologic data (weight, blood pressure, pulse oximetry, heart rate, glucose) and requires automatic device transmission. RTM treatment management codes can be billed by therapists and clinical psychologists in addition to physicians and APPs.

3. What CPT codes are used for RTM?

CPT 98975 initial setup and education, CPT 98976 respiratory device supply, CPT 98977 musculoskeletal device supply, CPT 98978 CBT device supply, CPT 98980 first 20 minutes treatment management, CPT 98981 each additional 20 minutes.

4. When did RTM become effective under Medicare?

January 1, 2022, under the CY 2022 Medicare Physician Fee Schedule final rule.

5. What conditions are eligible for RTM?

Acute and chronic conditions requiring therapeutic monitoring. Common Georgia examples include post-orthopedic-surgery rehabilitation, chronic musculoskeletal pain, COPD management, post-pneumonia monitoring, depression management with CBT, and anxiety management with CBT.

6. Can patient-reported data be used under RTM?

Yes. This is a defining structural distinction from RPM. RTM allows patient-reported data captured through FDA-cleared apps and platforms. RPM requires automatic device transmission with no patient self-entry.

7. What is the 16-day measurement requirement?

CPT 98976 and 98977 require at least 16 days of measurements within a 30-day period to support billing. Less than 16 days means the device-supply code cannot be billed for that cycle.

8. What is the 20-minute interactive communication requirement?

CPT 98980 requires at least 20 minutes of RTM treatment management services in a calendar month, including at least one episode of interactive communication (synchronous audio-video, audio-only telephone, or other real-time interactive modality) with the patient or caregiver.

9. Who can bill RTM treatment management?

Physicians, NPs, PAs, CNSs, CNMs, and — uniquely under RTM — physical therapists, occupational therapists, speech-language pathologists, and clinical psychologists when furnishing within their scope of practice.

10. Does the device have to be FDA-cleared?

Yes. RTM devices must meet the FDA definition of a medical device under section 201(h) of the Federal Food, Drug, and Cosmetic Act, typically cleared under 510(k), De Novo, or PMA pathways.

11. Is RTM covered under telehealth?

Yes, including for the interactive communication component. Both synchronous audio-video and audio-only telephone interactive communication are supported.

12. What is the cost to the Georgia beneficiary?

Standard Part B cost-sharing — annual Part B deductible plus 20% coinsurance. Typical monthly total: $15–30. QMB beneficiaries pay nothing. Medigap and Medicare Advantage coverage vary by plan.

13. Can a beneficiary receive both RTM and RPM at the same time?

Yes, for different monitoring episodes. A beneficiary may receive RPM for heart failure weight monitoring and RTM for knee rehab range-of-motion monitoring in the same calendar month. They cannot both apply to the same monitoring episode.

14. Can RTM be billed alongside Chronic Care Management (CCM)?

Yes, in the same calendar month. Time tracked must be distinct between the two services.

15. Can RTM be billed alongside Principal Care Management (PCM)?

Yes, in the same calendar month, with distinct time tracking.

16. Can RTM be billed alongside Behavioral Health Integration (BHI)?

Yes. RTM CBT monitoring (98978) and BHI services can coexist with distinct documentation. The services cover different work — BHI covers psychiatric consultation and care management integrated in primary care; RTM 98978 covers device-supported CBT monitoring.

17. Can RTM be billed alongside Transitional Care Management (TCM)?

Yes. TCM covers the 30-day post-discharge transition; RTM continues therapeutic monitoring through and beyond that period.

18. Is patient consent required for RTM?

Yes. Verbal or written consent must be documented in the medical record at initiation, covering the service, expected cost-sharing, ability to discontinue, and data flow.

19. What if my patient cannot achieve 16 days of measurements?

The device-supply code cannot be billed for that 30-day cycle. Reinforce patient education, investigate device or connectivity issues, and consider whether RTM remains the right service.

20. What is the single practitioner per month rule?

Only one practitioner may bill RTM services per patient per 30-day period for the same monitoring episode. Patient retains choice of practitioner; coordination among clinicians supports designation.

21. Can a physical therapist bill RTM treatment management codes?

Yes. Physical therapists are explicitly within the qualified professional scope for CPT 98980 and 98981 when furnishing within their scope of practice and consistent with the plan of treatment.

22. Can a clinical psychologist bill RTM treatment management codes?

Yes. Clinical psychologists are within the qualified professional scope, particularly relevant for CBT RTM under CPT 98978.

23. Does Medicare Advantage cover RTM?

Yes. All Medicare Advantage plans must cover services that Original Medicare covers, including RTM. Cost-sharing varies by plan.

24. Where can Georgia beneficiaries find RTM programs?

Major health systems statewide (Emory, Wellstar, Piedmont, Augusta University, Atrium Health Navicent, Memorial Health, Phoebe Putney, Northeast Georgia, Atlanta VA), large outpatient therapy networks (BenchMark, Drayer, Athletico), pulmonary rehab programs, and behavioral health practices delivering CBT.

25. How do I appeal an RTM coverage denial?

Standard Medicare appeals process — redetermination by the MAC (Palmetto GBA in Georgia), reconsideration by the QIC, ALJ hearing, Medicare Appeals Council, and federal district court. GeorgiaCares SHIP (1-866-552-4464) provides free counseling.

Why RTM coverage matters for every Georgia Medicare beneficiary needing therapeutic monitoring

RTM completes the Medicare remote monitoring architecture in two important directions. First, it extends remote monitoring into therapeutic data beyond physiologic data — the daily exercise completion, the inhaler use, the CBT homework, the symptom diary, the pain scale. Second, it extends the qualified professional scope to include therapists and clinical psychologists, recognizing that the clinicians most involved in the underlying therapeutic work should be able to bill for the time spent monitoring and managing that work remotely.

For Georgia Medicare beneficiaries, the practical consequence is access. A 70-year-old in Fulton County recovering from total knee arthroplasty can stay on track with home exercises because the therapist is reviewing daily data and intervening when adherence slips. A 68-year-old in DeKalb County with COPD can avoid an emergency department visit because the pulmonary rehab program is tracking symptom severity and inhaler use and pulling the patient in early when warning signs appear. A 65-year-old in Bibb County with depression can sustain CBT progress because the psychologist is reviewing mood data and CBT homework between sessions.

For rural Georgia, RTM matters even more. Specialty therapy access concentrates in metropolitan areas. RTM brings expert monitoring into rural homes through telehealth interactive communication, patient-reported data capture, and audio-only telephone management when video is not available. The same therapist, psychologist, or pulmonary rehab program that historically served only a 30-mile catchment can extend therapeutic oversight across hundreds of miles through RTM.

Every Georgia Medicare beneficiary with a musculoskeletal, respiratory, or CBT-monitored therapeutic need should know that RTM exists, that it complements rather than duplicates RPM, and that qualified Georgia therapists, psychologists, physicians, and APPs can deliver and bill for the monitoring work that sustains therapeutic progress between in-person visits.

Resources and contacts

• Medicare: 1-800-MEDICARE (1-800-633-4227)
• Palmetto GBA MAC: 1-866-238-9650
• DCH Medicaid Member Services: 1-866-211-0950
• GeorgiaCares SHIP: 1-866-552-4464
• Medicare Rights Center: 1-800-333-4114
• Georgia Telehealth Resource Center
• American Physical Therapy Association
• American Occupational Therapy Association
• American Speech-Language-Hearing Association
• American Psychological Association
• COPD Foundation
• Atlanta Legal Aid: 404-377-0701
• Georgia Legal Services: 1-800-498-9469
• 211 Georgia
• Eldercare Locator: 1-800-677-1116
• Georgia DPH: 404-657-2700
• Acentra Health QIO: 1-844-455-8708
• Social Security Administration: 1-800-772-1213

This guide reflects Medicare RTM coverage as of 2026-05-14. RTM coverage is governed by the CY 2022 Medicare Physician Fee Schedule final rule effective January 1, 2022, and subsequent CMS guidance. For the most current coverage details, consult Medicare.gov, your MAC (Palmetto GBA in Georgia), and your treating Georgia health professional.