CPT 98981 is an add-on code for “Remote Therapeutic Monitoring” (RTM) treatment management. It covers each additional 20 minutes of non-face-to-face RTM services in a calendar month beyond the first 20 minutes (the first 20 min is CPT 98980). 1 2 By definition, 98981 is reported only in addition to 98980, and only when a full additional 20 minutes of work has occurred. 3 4 As with other RTM codes, there must be at least one two-way patient/caregiver contact (which can be by video or telephone) during the month to qualify. 2 (Texting or email alone does not meet this requirement.)
RTM codes were created for tracking non-physiologic health data – for example, therapy adherence or symptom response – and were recently extended to behavioral health. The AMA notes that RTM codes measure “therapy adherence and therapy response,” including review and monitoring of patient data related to those responses. New RTM codes specifically for cognitive behavioral therapy (CBT) were added in 2023. In that context, CPT 98981 is used by the provider to bill each extra 20 min of monthly remote management after the initial 20 min (CPT 98980). There must be at least one interactive communication with the patient or caregiver during the month for either 98980 or 98981. 5
RTM for mental health allows clinicians to remotely monitor and engage with patients between visits. For example, a patient might use a validated digital app or portal to log mood, anxiety or depression scores, medication use, sleep, or therapy homework completion. The clinician reviews this data each month and uses it to adjust treatment or intervene early. This can help track symptom trends and adherence to therapy or medications. CPT 98981 (with 98980) covers the clinician’s time to review these data and manage care.
Remote monitoring can include both objective data (e.g. activity tracker or sleep device readings) and subjective patient-reported data (e.g. a daily mood rating or symptom checklist). AMA commentary notes that RTM data “may represent objective device-generated integrated data or subjective inputs reported by a patient,” all reflecting therapeutic response. 5 In mental health, subjective data (journaling, PHQ-9 questionnaires, therapy adherence logs) are common. CPT 98981 is meant for the clinical management of such data: analyzing them, communicating with the patient, and updating the treatment plan. The goal is to improve outcomes by catching issues early – for example by identifying worsening symptoms or nonadherence that might otherwise lead to crisis. 6
CPT 98981 is reported by a physician or other qualified health professional (QHP) who is managing the patient’s care. 1 2 This includes psychiatrists, psychiatric nurse practitioners, physician assistants in behavioral health, and other licensed clinicians recognized by payers. (Medicare defines “other QHP” broadly, but in practice it means those who can bill medical services under their license.) A plan-of-care must typically exist: CMS placed RTM on the “therapy” code list. If a physical/occupational/speech therapist uses 98980/98981, it must be under a therapy plan (with GP/GO/GN modifiers). However, psychiatrists and similar clinicians may bill RTM outside a formal therapy plan (no therapy modifier needed). 1 Each service must be ordered by a physician/QHP as part of the patient’s treatment plan. 6 4
These services are furnished remotely (the patient at home, clinician in office or telehealth setting). Medicare specifically envisioned these services as delivered by therapists “remotely to beneficiaries in their homes” 1, and the setup (CPT 98975) can even occur in the patient’s home. For small or private practices, RTM typically involves having the patient use an approved device or app at home, then the clinician (or clinical staff under supervision) monitors the data and contacts the patient as needed. Documentation and billing still occur under the provider’s usual practice location (see “Telehealth Considerations” below).
Time minimums: You must document at least 20 minutes of combined RTM management time in the month to bill any code. CPT 98980 covers the first 20 min; CPT 98981 covers each additional 20 min block. APTA guidance confirms “Do not report 98980, 98981 for services of less than 20 minutes.”. Thus, if you spent 35 minutes on RTM this month, you would bill CPT 98980 only (20 min) and cannot bill 98981 (since full 40 min not reached). If you spent 60 min, you would bill 98980 once plus 98981 twice (one for the extra 20 min to 40 min, and another for 40–60 min). 3
Interactive communication: At least one synchronous contact each month is required (phone or video). APTA notes the required interaction “must be synchronous in person or via telephone or video” and that “minutes spent in the interactive communication cannot be counted toward any other code.”. 4 In practice, this means if you have a 15-minute video check-in to meet the interactive requirement, those 15 minutes count toward the 20-minute total for 98980/98981, and cannot also be billed as a separate E/M or telephone visit.
Devices and data: The data must come from an FDA-defined medical device or system. For example, if tracking sleep or activity, use a medical-grade wearable or software platform approved as a device. (Medicare guidance explicitly requires the device be FDA-defined. 4 The patient’s device (or app) should collect the relevant data and transmit it securely. Document the device(s) used, data collected, and how they relate to therapy adherence or response. For example, note that “Patient reported PHQ-9 scores and adherence data from [AppName] were reviewed.”
Documentation: Each 20-minute block must be documented in the patient’s record. Include date(s) and total time spent reviewing data or managing therapy, details of the interactive communication (date, duration, content), and any decisions made. Note that 98981 is add-on to 98980: you must also document the first 20 min that triggered 98980. Record patient consent to monitoring if required by payer (Medicare requires documented consent). 8 Any physician or QHP order for RTM services should be in the chart. Keep a running tally of cumulative RTM time each month. (Some practices chart a “remote monitoring log” or use the EHR care plan to track these minutes and contacts.)
CPT Coding: 98981 is an add-on code: it always accompanies 98980. Bill 98980 for the first 20 min, then 98981 for each extra 20. APTA notes “Basic Code 98980 and Add-on Code 98981 are reported together … based on the total [monthly] hours”carecloud.com (i.e. you tally after the month ends). You cannot bill 98981 on its own, and you cannot count the same minutes for 98980/98981 and also for another time-based code (like chronic care management or another time-based telehealth service). 4 8 Also, 98981 (and 98980) should generally not be billed on the same day as a face-to-face E/M by the same provider, since its time is separate.
Medicare: CMS classifies 98980/98981 as “sometimes therapy” codes. Thus, therapists (PT/OT/SLP) may use them under therapy plans (with appropriate modifier) and must be supervised per therapy rules. However, physicians and other practitioners can bill these outside a therapy plan (no modifier needed). 1 In Medicare’s fee schedule, note that these are not listed as telehealth; you use the POS where you (the billing provider) are located (e.g. POS 11 = office) and no Medicare telehealth modifier (95/GT) is required. Only one practitioner may bill RTM per patient in a 30-day period. Patient consent at time of service is required by Medicare, and the monitoring must be medically reasonable. Medicare does not allow CPT 98980/98981 to be billed concurrently with remote physiologic monitoring (RPM) or certain care-management codes if time overlaps. 8 (For example, you cannot bill the same minutes as both RTM and CCM.) Check Medicare local coverage or MLN articles for any state-specific edits.
Commercial Payers: Policies vary. Many commercial carriers follow Medicare’s definitions, but some have their own RTM policies. For instance, Anthem’s policy lists 98980-98981 under covered RTM codes and emphasizes that data must reflect therapy adherence/response. Generally, insurers will require that RTM services be medically necessary (e.g. patient at risk of deterioration without monitoring), ordered by a qualified provider, and meet all coding rules. 6 Always verify eligibility and billing rules with the patient’s insurer. Behavioral health parity laws may ensure insurers cover tele-behavioral services comparably, but RTM is a new modality – check each payer’s guidelines. Some commercial mental health payers have begun to explicitly cover RTM (especially for CBT), recognizing the AMA’s addition of codes like 98978 (CBT device supply) alongside 98980/98981. 5
Aggregating units: CPT and most guidelines allow multiple units of 98981 in one month (each unit = 20 min). For example, if a clinician spends 80 minutes in remote management in a month, they could bill 98980 + 98981×3 (for 20+60 mins). APTA notes that 98981 “can be reported three times and billed up to 80 min” 7, though ultimately any full 20-minute block beyond the first can be billed until work is done. Practically, most clinicians cap it around three or four units, since very high time may trigger review.
Although CPT 98981 represents remote (non–face-to-face) care, it is not billed as a standard telehealth visit. No telehealth modifier (e.g. 95/GT) is attached, and you use the provider’s place of service (generally the office or clinic). However, the required interactive contact may occur via telehealth (video) or even by telephone. 4 If you conduct that synchronous check-in by video conference as an actual “telehealth visit,” you could also bill a separate appropriate E/M or therapy code for that visit (if it meets all other criteria), but you must not double-count time already included in 98980/98981. In other words, allocate the minutes carefully between the RTM time code and any billed telehealth E/M.
Some states have telehealth reimbursement parity laws for mental health, meaning insurers must cover tele-behavioral services similarly to in-person ones. While these laws often address live visits, the RTM codes align with the broader move to cover remote care. Medicare’s COVID-era flexibilities (extended through 2025) continue to allow broad tele-mental health services; RTM complements those by covering asynchronous monitoring. For EHR workflow, treat RTM notes as you would a non-face-to-face CCM or care management service: document in the patient’s medical record, include the time in your billing note, and mark that it was “telehealth/remote monitoring.”
Implementing RTM in a practice requires some planning. Clinicians should integrate a remote monitoring platform or app that patients can use to log data. The platform ideally connects to the EHR or patient portal (for example, via an API or secure export) so that patient data flows into the chart or is readily accessible for review. If direct integration isn’t available, staff can import or transcribe the patient’s reported data. The EHR should have a template or flowsheet for RTM that records the dates of data review, minutes spent, and patient communications. It may be helpful to create an RTM workflow checklist: patient consent, device setup (CPT 98975), monthly data collection, clinician review (time tracking), one synchronous check-in, and documentation of any plan changes.
Key documentation elements in the EHR include: the treatment plan or order for RTM, the data summaries reviewed (e.g. mood scores over the month), the dates and duration of clinician time, and notes on the interactive encounter (whether by phone or video). The EHR plan of care or problem list can note that the patient is enrolled in RTM, with alerts for when 20 minutes of work has been logged. Non-promotional tip: many EHRs support connecting mobile apps or patient portals (like patient questionnaire tools) where patients can enter mental health scores; use these if available to streamline data capture. Staff training is important so everyone understands that time spent on remote monitoring (and the required contacts) is billable under 98980/98981.
For clinicians, CPT 98981 (with 98980) provides a way to get reimbursed for valuable remote care time. Rather than losing this work, providers can bill it when clinically appropriate. The codes encourage a structured approach to follow-up: reviewing patient-tracked symptoms and intervening as needed. Early intervention (for example, adjusting therapy when a patient’s depression score spikes) can improve outcomes and reduce crises. As Anthem’s policy notes, RTM data can help manage chronic conditions under a treatment plan and “prevent avoidable deterioration in the clinical condition,” potentially preventing rehospitalizations or emergency visits. 6 Integrating RTM can also enhance patient engagement – knowing that their daily inputs are reviewed may motivate patients to stick with treatment.
For patients, RTM means more connected care. They can stay at home while still receiving attention from their therapist. Patients who have difficulty coming in for frequent visits (due to transportation, mobility, or anxiety) benefit from knowing their provider is monitoring their progress remotely. Easy symptom logging or wearable data can give patients real-time feedback on their condition. Ultimately, the convenience and support of RTM can improve adherence to therapy homework and medication, and can catch problems before they worsen. Clinical reports suggest that remote monitoring (even of psychological states like mood) can lead to better control of conditions than infrequent office visits aloneanthem.com.
In summary, CPT 98981 is a timely tool for behavioral health professionals to extend care beyond the clinic. By following the detailed coding rules and documentation requirements, small practices can add this service in both in-person and telehealth settings, ensuring patients benefit from continuous care while practices capture the associated reimbursement.
Sources:
CMS – CPT Code 98981: Medicare Claims Processing Manual
https://www.cms.gov/files/document/r11118cp.pdf
AAPC – CPT® Code 98981 - Remote Therapeutic Monitoring Treatment Management Services
https://www.aapc.com/codes/cpt-codes/98981
American Medical Association (AMA) – Digital Medicine Clinical Scenarios: Coding Handbook
https://www.ama-assn.org/system/files/digital-medicine-clinical-scenarios-coding-handbook.pdf
American Physical Therapy Association (APTA) – Practice Advisory: Remote Therapeutic Monitoring Codes Under Medicare
https://www.apta.org/contentassets/95321a10e951408db650e2f19b96699f/apta-practice-advisory-rtm-codes032023.pdf
AMA – These Are the Mental Health Care CPT Code Changes to Know in 2023
https://www.ama-assn.org/practice-management/cpt/these-are-mental-health-care-cpt-code-changes-know-2023
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 98981
https://www.carecloud.com/cpt-98981/
Telehealth.HHS.gov – Billing for Remote Patient Monitoring
https://telehealth.hhs.gov/providers/best-practice-guides/telehealth-and-remote-patient-monitoring/billing-remote-patient
