CPT code 98980 is part of the new Remote Therapeutic Monitoring (RTM) code family. It covers the first 20 minutes of clinician time per calendar month dedicated to remote monitoring and management of non–physiological patient data (e.g. symptom/mood tracking, therapy adherence) for a patient under a treatment plan. 1 2 In practice, 98980 applies when a provider (physician or other qualified health professional) spends ≥20 minutes in a month reviewing patient-reported data and communicating with the patient or caregiver about their treatment. This includes at least one interactive communication (phone or video) during the month. (Each additional 20 minutes beyond the first is reported with add-on code 98981. 3) Unlike traditional telehealth visit codes, 98980 is intended for ongoing chronic care management using data collected remotely (for example, via apps or devices), rather than a single face-to-face encounter.
Though initially introduced for musculoskeletal and respiratory monitoring, RTM explicitly encompasses therapy-related data. In behavioral health, 98980 can support tracking of treatment engagement and symptoms. For example, patients might use a secure app or online questionnaire to log daily mood ratings, anxiety or depression scores, therapy homework completion, medication compliance, sleep quality, or stress levels. These data are then reviewed by the provider, who checks in with the patient (by phone/video) to interpret the results and adjust the care plan. CMS’s Medicare Learning Network describes RTM as capturing “non-physiological” patient data related to therapy, including treatment adherence and response. 1 2 Anthem’s policy notes that RTM technology can monitor psychological variables (e.g. depression and mood) more frequently than office visits. (Indeed, AMA recently added CPT 98978 for device-supply monitoring of cognitive behavioral therapy as a specific use-case. 4) In short, 98980 lets mental health providers bill for the time spent remotely reviewing behavioral health data (mood scores, journal entries, app interactions, etc.) and then actively managing the patient’s treatment plan via tele-support.
CPT descriptors specify that 98980 is reportable by a “physician or other qualified health care professional”. In practice, this includes physicians (MD/DO) and most non-physician practitioners (NPs, PAs, CNS) who are licensed to evaluate and manage patients. Medicare treats 98980 as a ”sometimes therapy” code: physicians and NPPs may furnish it outside a therapy plan-of-care, while physical/occupational/speech therapists (PT/OT/SLP) can furnish it under their therapy plan with the appropriate therapy modifier (GP, GO or GN). 1 Although primarily designed for medical providers, some professional sources note that clinical social workers and other therapists could also bill RTM codes when they meet licensing requirements. 5 (For example, a clinical social worker or psychologist might use 98980 when reviewing patient-reported behavior data and providing feedback as part of a care plan.)
RTM services are delivered remotely (patient at home, provider at office or clinic). Medicare specifically envisioned 98980 being furnished by therapists “in their homes” or by therapists in private practice. 1 In small or private behavioral health practices, 98980 can be used whenever the practice has a setup for remote monitoring (e.g. an approved app or device and a means to communicate with the patient). It is not limited to large hospitals or telehealth platforms; outpatient clinics and individual practitioners can implement RTM using secure video visits or even phone calls (with data review done beforehand) to meet the interactive communication requirement.
Code 98980 covers the first 20 minutes of cumulative provider time per calendar month spent on RTM treatment management. This 20-minute total can include reviewing incoming patient data (for example, a week’s worth of mood logs) and then communicating with the patient (or caregiver). Critically, at least one live (interactive) contact must occur each month (via phone or two-way video) to bill 98980. If the combined review-and-communication time exceeds 20 minutes in that month, the additional time is billed with 98981 (each unit = 20 extra minutes). (For example, a provider who spends 35 minutes total would bill 98980 plus one unit of 98981.) Documented time should be logged in minutes. Providers should not bill 98980 unless a full 20 minutes of RTM management has occurred. 3 The codes are reported on a calendar-month basis – they reset at the start of each month.
To support billing, clinicians must clearly document the RTM service. Good practice is to note the device or tool used, the type of data collected (e.g. daily PHQ-9 scores, medication adherence logs, CBT app metrics), and the dates covered. Then record the date and duration of each patient/caregiver interaction and a summary of what was done. The Medicare learning network and coding guidance suggest documenting the specific data reviewed from the device or app, the date/time of any patient contact, and any clinical decisions (e.g. medication change, therapy recommendation) made as a result. 3 In mental health, this might mean writing in the note: “Reviewed patient’s weekly mood survey data (via secure app). On 6/12/25, conducted a 15-minute video call to discuss increased anxiety; adjusted coping plan accordingly.” Also note any education given or devices set up (CPT 98975) or devices supplied (98976/98977/98978) earlier, if applicable. In summary, documentation should support: one interactive contact, roughly 20+ minutes of work, the nature of the data and device, and how the patient’s treatment was managed.
Billing Rules and Payer Policies: Important rules include:
Medicare Coverage: Medicare does cover RTM (codes 98975–98981) under Part B when medically necessary. CPT 98980 was added to the therapy code list as “sometimes therapy”. That means physicians, NPs, and PAs can bill it under regular Part B (no therapy plan needed), while therapists must include it under a therapy plan with modifier GP/GO/GN. 1 Only one practitioner may bill RTM per patient per 30-day period (similar to RPM rules). Medicare specifically requires no minimum “established patient” rule for RTM (unlike RPM). The related device-supply codes (98976, 98977, 98978) each require at least 16 days of monitoring in 30 days, but 98980/98981 have no 16-day minimum requirement. 6 7 (In short, once devices are set up, you can bill RTM management even if the patient doesn’t transmit data every day.) CMS also clarifies that you cannot bill RPM (99457/99458) and RTM (98980/98981) concurrently for the same patient – choose the service that matches the data being monitored. RTM time cannot overlap with time billed under other management codes (e.g. CCM, TCM, BHI) – each service must have distinct time documentation. (It is allowed, however, to bill RTM and chronic care management in the same month if they are separate efforts with separate notes.) 6
Commercial Payers: Private insurers generally follow AMA and Medicare guidelines but should always be checked for specifics. For example, Anthem’s medical policy explicitly lists 98980/98981 (and even 98978 for CBT) as billable RTM codes under their “digital health monitoring” services. 4 Many commercial plans now accept telehealth-delivered behavioral health and related codes, often with reimbursement parity. Always verify if an insurer requires pre-authorization or specific place-of-service rules for RTM. Many state telehealth laws mandate that private payers reimburse telehealth services (including RTM) at in-person rates.
Place-of-Service and Modifiers (Telehealth): CPT 98980 itself does not carry a special “telehealth” modifier, but Medicare and other payers require correct place-of-service codes. For Medicare, as of 2024 providers should use POS 02 for telehealth delivered outside the patient’s home, and POS 10 for telehealth in the patient’s home. (CMS no longer requires modifier 95 for professional telehealth claims; the POS suffices.) Note that Medicare considers RTM codes payable when performed via telehealth: for example, the MLN explicitly marks 98980 as telehealth‐eligible. When billed with POS 10 (patient at home), Medicare pays at the non-facility rate (the same amount as in-office). 2 (Under current rules, 98980 is not on the permanent Medicare telehealth list; it has been reimbursed under COVID waivers and later PFS rules, but providers should confirm ongoing policies.) For private payers, follow each plan’s telehealth rules (many mirror Medicare). Always document that the patient was outside a clinic setting and that a live interactive modality was used.
Modifiers: Aside from POS, Medicare requires therapy modifiers for PT/OT/SLP providers billing RTM (GP/GO/GN) since it’s on the therapy list. Physicians and NPPs do not attach those. No special RTM-specific modifier exists (unlike RPM’s –95 for asynchronous, etc.). If using ancillary staff (nurses, medical assistants) to gather or review data, Medicare allows “general supervision,” and the physician/NPP still bills 98980 for their time. 1
Claims and Frequency: Report 98980/98981 on a monthly basis. The base code (98980) can be billed only once per month; 98981 is added for extra time. The device-supply codes (98976/77/78) and setup code (98975) are also once-per-30-day codes. Take care not to double-bill: do not report 98980 if you have already billed 99457/99458 (RPM) for the same data in that month, and vice versa. If a patient switches devices or programs, some payers might allow a new 98975 setup code (one-time) as needed.
RTM by definition is a remote service. Medicare permits billing 98980 when delivered via telehealth under the rules above. 2 State and commercial telehealth laws may impose additional requirements (e.g. consent, specific modifiers, or technology standards), so follow those as well. Remote monitoring often blurs into broader care coordination: it cannot replace necessary in-person therapy sessions when those are indicated, and services billed must be reasonable and documented as such. New for 2024–2025, telehealth parity rules in many states mean private insurers must pay remote behavioral health services at rates similar to in-person – a positive for 98980 utilization. Always code the place of service based on where the patient was (not where the provider is) and append any required telehealth modifiers per payer guidelines.
Successful RTM requires good workflows and documentation. Clinicians should use FDA-cleared devices or apps for data collection. (CMS expects that the monitoring tool meets the FDA’s definition of a medical device; for example, a validated mood-tracking app or a digital therapeutic platform.) Data should be collected electronically and, if possible, automatically uploaded to a secure system. The provider’s EHR or portal can be used to capture this data: for instance, patients might enter responses to a validated PHQ-9 questionnaire in the patient portal, or a mobile app could feed symptom scores into the record. Whether data are auto-imported or entered manually, document the key findings (e.g. survey results, medication logs) in the chart. Maintain a log of communications: note date, time, duration, and medium of each interaction (Anthem stresses HIPAA-compliant transmission and logging of all connections). 4 In practice, clinics often create a simple flowsheet or note template for RTM. For example, a note could include headings like “Device/Data Reviewed,” “Time Spent,” “Communication Summary,” and “Plan/Follow-up.” If the patient required setup or education on a device, document that under 98975 (and bill once if not already done). Integrating RTM tasks into the EHR workflow might involve assigning staff to remind the clinician when a patient’s monthly RTM period is due, or using ticklers to prompt data review.
RTM codes like 98980 recognize and reimburse valuable non-face-to-face work. For clinicians, billing 98980 compensates time spent monitoring remote patient data – time that previously went unpaid. It encourages use of digital tools (apps, wearables) that can enhance therapy. For patients, RTM means more continuous support: rather than waiting weeks for the next office visit, patients get regular check-ins based on their own reported experiences. This can improve adherence to therapy assignments and medication regimens and catch deteriorations early. Anthem’s policy notes that RTM ”has the potential to prevent avoidable deterioration in the clinical condition” and reduce ER visits. In behavioral health, routine symptom tracking (e.g. daily mood, sleep patterns, stress) can help clinicians adjust treatment plans faster, tailor interventions, and keep patients engaged between sessions. Many providers find that even a 10–15 minute monthly call with data in hand can strengthen the therapeutic alliance and lead to better outcomes. 4
In summary, CPT 98980 enables behavioral health clinicians to formally bill for remote monitoring and management of patient-reported outcomes. When implemented correctly – using FDA-approved tools, following telehealth billing rules, and thoroughly documenting – it can extend care beyond the office, improve patient engagement, and generate additional revenue for practices. 4
Sources:
CMS – Medicare Claims Processing Manual: CPT Code 98980
https://www.cms.gov/files/document/r11118cp.pdf
CMS – MLN901705: Telehealth & Remote Patient Monitoring
https://www.cms.gov/files/document/mln901705-telehealth-remote-patient-monitoring.pdf
MedBridge Help Center – What are the new RTM CPT codes?
https://support.medbridge.com/hc/en-us/articles/12219842491923-What-are-the-new-RTM-CPT-codes
Anthem – CG-MED-91: Remote Therapeutic and Physiologic Monitoring Services
https://www.anthem.com/dam/medpolicies/abc/active/guidelines/gl_pw_e001871.html
CareCloud – Remote Therapeutic Monitoring – CPT Code 98980
https://carecloud.com/cpt-98980/
Telehealth.HHS.gov – Billing for Remote Patient Monitoring
https://telehealth.hhs.gov/providers/best-practice-guides/telehealth-and-remote-patient-monitoring/billing-remote-patient
Foley & Lardner LLP – Top 5 Rules for Medicare 2024 Remote Patient Monitoring and Remote Therapeutic Monitoring
https://www.foley.com/insights/publications/2023/11/top-5-rules-medicare-2024-rpm-rtm
