What is CPT 98975 and When Is It Used? CPT 98975 is the code for the initial setup and patient education on a remote therapeutic monitoring (RTM) system. 1 In behavioral health, RTM includes tracking non-physiological data related to therapy (for example, mood, medication adherence, or exercises) using digital tools. 2 Code 98975 is billed once at the start of an RTM “episode” when a patient is onboarded to a monitoring system (such as a CBT app, wearable device, or mobile therapy platform). It covers activities like configuring the device or app, explaining how to use it, and answering patient questions about logging data. CPT 98975 can only be billed once per episode of care and only after the patient has begun data collection (typically ≥16 days of use). 3 Clinical documentation must record the device/app used, what training was provided, and confirm patient activation of the monitoring tool.
Remote therapeutic monitoring often uses digital health tools (for example, video apps or browser-based mood trackers) to let mental health patients log symptoms and treatment adherence outside the office. 2 In this context, 98975 funds the in-person or at-home session where the clinician or trained staff help the patient install and learn a qualified medical device or software. For example, a therapist might guide a patient through a smartphone CBT app setup or teach them how to wear and sync a biometric sensor. The code’s CPT descriptor emphasizes “initial set-up and patient education on use of equipment”. 1 This one-time service lays the foundation for ongoing RTM by ensuring the patient knows how to report their progress or symptoms to the care team.
How RTM Codes Relate (98976–98981). The RTM code family builds on 98975. Key related codes include:
CPT 98976: Monthly supply of a device for respiratory status monitoring. Requires ≥16 days of data transmission in the 30-day period. 3 (E.g., a Bluetooth peak flow meter for asthma.)
CPT 98977: Monthly supply of a device for musculoskeletal status monitoring. Also requires ≥16 days of data. 3 (E.g., a wearable motion sensor to track activity for back pain.)
CPT 98978: New for cognitive behavioral therapy (CBT). Covers monthly device supply or digital therapeutic used for CBT monitoring. 4 This code was specifically added for mental health use, covering software or devices that prompt CBT exercises or track mood/anxiety symptoms.
CPT 98980: RTM treatment management, first 20 minutes per month. This is billed when the provider (MD, NP, PA, etc.) reviews the data and interacts with the patient or caregiver about the therapy. The code requires at least one two-way communication per month and covers the first 20 minutes of that clinical work. 5
CPT 98981: RTM treatment management, each additional 20-minute increment (add-on to 98980). Used if more than 20 minutes of interaction time are spent in the month. 5
Together, 98975 sets up the monitoring, 98976–98978 supply the actual devices/software, and 98980–98981 pay for the clinical time managing the remote therapy data. (All device/supply codes require 16+ days of data collection before billing in a 30-day period.) 3 6
Devices used for RTM in behavioral health can range from smartphone apps to specialized equipment. For example, a virtual reality (VR) headset may deliver guided relaxation or exposure therapy exercises. CPT 98975 applies to onboarding any qualifying medical device or software – whether it’s a VR headset, a tablet app, a biofeedback band, or other FDA-defined device. 3 The photo above illustrates a patient using a therapeutic device; the onboarding and education for such a device would be coded as 98975. In summary, 98975 funds the technical setup: installing the app or device, demonstrating its use, and confirming that the patient is ready to transmit data back to the therapist.
Providers: Medicare classifies 98975–98981 as “sometimes therapy” codes. This means that physicians and qualified non-physician practitioners (NPPs) – such as MDs, DOs, NPs, PAs, and clinical nurse specialists – can bill 98975 on their own. They do not need an underlying therapy plan-of-care. By contrast, physical therapists (PTs), occupational therapists (OTs), and speech therapists can also furnish RTM services, but only under a therapy plan with the appropriate modifier (GP, GO, GN). 1 (Behavioral health providers like psychologists or social workers are generally not recognized as “therapy” providers under Medicare for these codes, so check payer policy.) In practice, a small private behavioral health practice with an MD, NP, or PA can directly bill 98975; if a PT or OT (for example, in integrated rehab/behavioral practice) provides the service, the bill must be under a therapy authorization.
Settings: Code 98975 is intended for in-person instruction. Medicare’s guidance states the initial setup/training is done either in the clinic or the patient’s home. 1 (In the home, use Place of Service (POS) 12; in the office, use POS 11.) Importantly, 98975 is not on Medicare’s approved telehealth list. 6 This means that under current rules you cannot bill 98975 as a telehealth visit (POS 02). If the clinician or therapist delivers the training in person at the patient’s home or office, 98975 is billable. If it is done over video or phone, Medicare will not cover 98975 (other non-RTM telehealth codes must be used instead). If the service is performed by ancillary staff (for example, a nurse or therapist assistant under general supervision), Medicare requires direct supervision of the billing provider. 1
Provider Order and Medical Necessity: An eligible provider (MD, DO, NP, PA, or PT under plan) must order the RTM service and device. The order and chart must reflect a legitimate behavioral health need (e.g. therapy adherence monitoring). Patient consent for remote monitoring should be documented (Medicare requires consent for RPM/RTM). 2 The device used must be defined as a medical device by the FDA 3 (most certified therapy apps and wearables qualify).
Training Content: Document the date and time of the setup session, the specific device/app (make and model or software name), and the education given. Note what instructions were provided (e.g. how to open the app, record data, charge the device, transmit readings) and confirm that the patient (or caregiver) understands. If the patient activated the device/app during the visit, record the activation steps.
Data Requirements: Before billing 98975, the patient must start using the device and generate data. Medicare guidance specifies at least 16 days of data collection in a 30-day period. 3 In practice, plan to bill 98975 on or after day 17 of monitoring to meet this threshold. Track the first day of data so you know when that mark is reached.
One-Time per Episode: CPT 98975 is a one-time code per “episode” of an RTM program. An episode of care may coincide with a course of therapy. You should not bill 98975 repeatedly for the same RTM plan. If a patient stops and later restarts with a new device or app, a new episode would justify another 98975.
Modifier 25: If an evaluation-and-management (E/M) office visit occurs on the same day as the 98975 setup (for example, a therapy session where setup also happens), append modifier 25 to the E/M code. This distinguishes the separately billable device training from the visit itself.
Supervision: When 98975 is performed by non-billing staff, ensure direct supervision. For example, if a physical therapist assistant teaches the device, the PT must be on premises and immediately available. 1
Medicare (CMS): Under Medicare Part B, RTM codes are included on the therapy code list. CMS treats 98975 as “sometimes therapy”: physicians and NPPs bill outside a therapy plan, while PTs/OTs bill under a therapy plan (with modifiers). 1 An established physician-patient relationship is not strictly required for RTM (unlike RPM). Key rules include obtaining patient consent and billing only after 16 days of monitoring. 2 3 Only one provider may bill these RTM codes per patient per month, and RTM codes cannot be billed concurrently with any remote physiologic monitoring (RPM) codes. 2 98975 itself is always an in-person/home service for Medicare, and not a telehealth service. 6 Payment for 98975 is a flat fee (e.g. ~$19 in recent fee schedules), reflecting its one-time nature.
Commercial Payers: Coverage policies vary. Many commercial insurers broadly follow Medicare’s framework but may have additional requirements (such as pre-authorization or limited covered devices). For example, Anthem’s policy explicitly lists CPT 98975–98981 as RTM services and even includes 98978 for cognitive behavioral therapy. 4 Private plans may allow licensed mental health counselors or psychologists to bill these codes (Medicare does not), so check each insurer’s policy. Generally, insurers will require documentation of medical necessity and adherence to coding rules (FDA-approved device, daily data reporting, etc.). Since commercial rules can differ (for instance on telehealth billing or episode length), verify details with each payer’s coverage guidelines.
To implement 98975 smoothly, build it into your clinical workflow:
Order Sets/Tasks: Create an EHR order or checklist for RTM onboarding. Include fields for device type, start date of monitoring, and consent. Assign a follow-up task or reminder around day 16 to verify data collection.
Documentation Templates: Use progress note templates that prompt for device details, patient instructions given, and initial patient-reported values. This ensures all billable elements are captured.
Patient Portal/Telehealth Tools: If your EHR has patient portal or telehealth functionality, use it to send app links, training videos, or questionnaires. Record any remote support interactions in the chart (these may count toward 98980/98981 if interactive).
Billing Alerts: Flag when 98975 becomes billable (after 16 days). Some practices use their practice management system to alert billing staff once an RTM episode hits day 17.
Interdisciplinary Support: In a small practice, delegate tasks where possible. Nurses or care coordinators can help set up devices and educate patients (under supervision), letting providers focus on clinical review.
CPT 98975 itself is not a telehealth service under Medicare. 6 Therefore:
Provide it in person (the clinician and patient must be co-located either in the clinic or home). Bill with POS 11 (office) or POS 12 (home). Do not use POS 02 or modifier 95 for 98975 under current Medicare rules. 6
By contrast, the RTM management codes (98980/98981) involve real-time communication and are telehealth-eligible. If you review the data and speak with the patient by video or phone, you can bill 98980/98981 with POS 02 (or appropriate telehealth place) and add modifier 95 (per payer) to indicate a telehealth encounter. 6
For private insurers, policies may differ: some may allow 98975 to be billed if education is given via live video (check payer guidelines). Always use the telehealth modifier and POS that comply with each payer’s rules.
Remote Support: CPT does not have a separate code for “device tech support.” If you provide follow-up clarifications (e.g., messaging about app use), that time may only be reported under 98980/98981 if it involves an interactive patient/provider encounter in the same month. General behind-the-scenes work or non-interactive portal follow-up is not separately billable beyond what 98975 and 98980/98981 cover.
Remote therapeutic monitoring can enhance behavioral health care and practice revenue. Studies and policy reviews note that monitoring psychological variables (like mood or therapy adherence) outside office visits can improve patient engagement and outcomes. For example, RTM gives therapists data on symptoms between sessions, allowing early intervention if issues arise. Increased “surveillance and support” through technology has the potential to improve treatment adherence and strengthen patient–provider communication. 4
For a small practice, billing 98975 (even at a modest rate) compensates the clinician’s time spent on training and expands the services offered. Over multiple patients, these reimbursements add up. Additionally, offering RTM can differentiate a practice with high-touch digital care. From a clinical standpoint, having structured remote check-ins can lead to better continuity for patients (especially those who struggle with in-person attendance). Overall, integrating 98975 and related RTM codes helps practices justify and be paid for modern, tech-assisted care that keeps patients actively involved in their behavioral health treatment. 4 Sources:
CMS – Medicare Claims Processing Manual (RTM Codes Overview)
https://www.cms.gov/files/document/r11118cp.pdf
Telehealth.HHS.gov – Billing for Remote Patient Monitoring
https://telehealth.hhs.gov/providers/best-practice-guides/telehealth-and-remote-patient-monitoring/billing-remote-patient
American Physical Therapy Association (APTA) – Practice Advisory on Remote Therapeutic Monitoring (RTM) Codes Under Medicare
https://www.apta.org/contentassets/95321a10e951408db650e2f19b96699f/apta-practice-advisory-rtm-codes032023.pdf
Anthem – CG-MED-91 Remote Therapeutic and Physiologic Monitoring Services
https://www.anthem.com/dam/medpolicies/abc/active/guidelines/gl_pw_e001871.html
American Medical Association (AMA) – As Remote Patient Monitoring Expands, So Does CPT to Describe It
https://www.ama-assn.org/practice-management/cpt/remote-patient-monitoring-expands-so-does-cpt-describe-it
CMS – MLN901705: Telehealth & Remote Patient Monitoring Guide
https://www.cms.gov/files/document/mln901705-telehealth-remote-patient-monitoring.pdf
