Remote monitoring billing in the U.S.: RPM versus RTM codes at a glance

Some topics don’t click until I map them to a real day in clinic. Remote monitoring billing was one of those for me. I kept seeing the same questions from teams—Which codes go with devices versus time? When do the “16 days” rules matter? Who can bill what?—and I didn’t want to memorize a wall of CPT numbers without feeling how they fit together. So I sat down, sketched my own one-page cheat sheet, and then pressure-tested it against the official guidance. What follows is my plain-English “at a glance” version of RPM (Remote Physiologic Monitoring) and RTM (Remote Therapeutic Monitoring) as they stand in 2025, with notes on the few places where nuance and judgment really matter. If you want an authoritative overview, the federal guide on billing for remote monitoring is a great jumping-off point here, and the CMS MLN booklet lays out the code scaffolding with helpful tables here.

The mental model that finally stuck for me

I stopped thinking “RPM vs RTM” and started thinking in two stacks:

  • Device stack (setup + supply/data days) — these codes hinge on whether enough data were captured in a 30-day span.
  • Management stack (time with the patient’s data and interactive care) — these codes hinge on minutes of work and require live back-and-forth (audio-only is allowed for the management minutes).

Everything else (who can bill, whether the device must be an FDA-defined medical device, whether data can be self-reported) flows from whether you’re in RPM—classic physiologic metrics like blood pressure or weight—or RTM—non-physiologic, therapy-oriented measures such as musculoskeletal or respiratory status, adherence, or response. The federal guide spells out those data differences clearly (including that only RTM can incorporate patient-self-reported data via the device) here.

One page, side-by-side

Here’s the quick comparison I keep on my desk. I wrote it to be skimmed in under a minute, but each line is anchored in current 2025 rules.

Topic RPM (Remote Physiologic Monitoring) RTM (Remote Therapeutic Monitoring)
What’s being tracked Physiologic metrics (e.g., BP, SpO2, glucose, weight). Therapy-related, non-physiologic data (e.g., musculoskeletal or respiratory status, adherence, response; CBT-related signals).
Device expectations Must be an FDA-defined medical device that automatically collects and uploads data. Connected therapeutic device transmits information; RTM uniquely allows some patient-reported inputs via the device.
“16 days” rule Applies to the device supply code (99454): ≥16 days of data in 30 days. Not required for management time codes (99457/99458). Applies to device supply codes 98976 (respiratory) and 98977 (musculoskeletal): ≥16 days in 30 days. Management time codes (98980/98981) don’t require the 16 days.
Setup & education 99453 (once per episode of care). 98975 (once per episode of care).
Device supply / data days 99454 each 30 days (≥16 days of transmitted data). 98976 (respiratory), 98977 (musculoskeletal) each 30 days (≥16 days). 98978 (CBT device supply) exists; pricing and contractor handling can vary—confirm with your MAC and payer policies.
Management minutes 99457 first 20 min; 99458 each additional 20 min; interactive communication required; audio-only allowed. 98980 first 20 min; 98981 each additional 20 min; interactive communication required; audio-only allowed.
Who can bill Physicians and non-physician practitioners eligible to furnish E/M. Auxiliary personnel may provide services under general supervision of the billing practitioner. Physicians and other qualified health care professionals (including PT/OT/SLP, consistent with state scope). General supervision can apply for incident-to structures where allowed.
Established patient status Required for RPM. Not required for RTM.
One-practitioner rule Only one practitioner may bill RPM in a 30-day period. RTM follows a similar one-practitioner-per-30-days logic for the relevant device/management codes.
Crucial caveats RPM and RTM can’t be billed together for the same period; they must be medically reasonable and necessary. They can be billed alongside CCM/TCM/BHI/PCM/CPM if time/effort aren’t double-counted, and documentation shows distinct work.

Those bullets align with two anchor references—the HHS telehealth billing page and the April 2025 CMS MLN booklet—which also clarify audio-only allowances for management minutes and the FDA-device requirement for RPM here and here. For broader 2025 payment context (conversion factor, supervision flexibilities through 2025, etc.), CMS posted a helpful fact sheet you can scan here.

How I decide RPM versus RTM in the moment

  • Start with the signal: Is the core data stream physiologic (BP, weight, pulse ox) or therapy-oriented (home exercise adherence, dyspnea score, cough frequency, pain with movement)? Physiologic → RPM. Therapy-oriented → RTM. This simple fork prevents most miscoding.
  • Ask if self-report belongs: If part of the signal is legitimately patient-reported (e.g., daily adherence check-ins embedded in a connected MSK app), that’s a nudge toward RTM. RPM’s device must automatically capture and transmit physiologic data without relying on self-report.
  • Map actions to stacks: Setup once per episode; device supply monthly (watch the 16-day rule where it applies); then management minutes monthly with interactive communication. If minutes are thin one month, you may have device supply without the time code—totally fine.

At first, I over-focused on code text and under-focused on documentation. Now I write my note as if I’m explaining the case to a colleague: what we monitored, why the device meets requirements, whether we hit ≥16 days for the supply code, what changed in the care plan after reviewing the data, and exactly how I communicated with the patient (including audio-only when that’s what happened). The MLN booklet literally itemizes these expectations, including the “≥16 days” rule for relevant codes and the audio-only allowance for management minutes here.

Code lists I keep handy

  • RPM: 99453 (setup/education, once per episode), 99454 (device supply, each 30 days, requires ≥16 days), 99457 (first 20 min management with interactive comms), 99458 (each additional 20 min).
  • RTM: 98975 (setup/education), 98976 (respiratory device supply, ≥16 days), 98977 (musculoskeletal device supply, ≥16 days), 98980 (first 20 min management), 98981 (each additional 20 min). There’s also 98978 tied to CBT-oriented device supply; the AMA’s 2025 CPT updates clarified the digital therapeutic context and device supply language across these codes—worth a quick glance here.

Little workflow habits that saved me denials

  • Calendar the 30-day windows: I note the device supply “from–to” dates and quickly verify the count of valid data days before 99454, 98976, or 98977. If we’re at 15 days, I nudge the team (or the app nudges the patient) rather than filing a claim that won’t meet the threshold.
  • Log the interaction details: For 99457/99458 and 98980/98981, I capture the minutes, the date(s), and the interactive element (phone, video, patient-portal live chat). Audio-only is acceptable for these management minutes per CMS, but you do need actual two-way interaction.
  • One-practitioner sanity check: Before billing, I confirm no other practitioner is filing the same family of codes for the same 30-day period. The federal guide explicitly reminds us “only one practitioner” can bill per period for RPM, and RTM follows a similar logic across device and management components here.
  • Keep scope and supervision straight: For RPM, auxiliary personnel can help under general supervision of the billing practitioner. RTM management can be furnished by qualified health professionals like PT/OT/SLP when state scope allows; in incident-to arrangements, verify your MAC’s rules.

Edge cases I’ve learned to pause on

  • New patient vs established patient: RPM requires an established relationship; RTM does not. If the clinical picture truly calls for RPM on day one, I schedule an E/M touchpoint first so the subsequent RPM is compliant.
  • Overlapping care management: It’s permissible to bill RPM/RTM alongside CCM, PCM, CPM, BHI, or TCM—but never count the same minutes twice. I literally draw a line through overlapping minutes in my scratch sheet to keep myself honest.
  • CBT-oriented RTM (98978): This one varies by contractor and payer on pricing/coverage. Before adopting a CBT device workflow, I reach out to our MAC and major commercial plans to confirm their stance (the AMA’s 2025 editorial updates signal the intent, but local payment can lag).

What might change next

Every summer, CMS proposes next-year tweaks to the Physician Fee Schedule. For 2025, the final rule set the table we’re using now; for 2026, the proposed rule hints at new flexibility around data-day ranges and time increments for remote monitoring. The official CMS fact sheets and Federal Register entries are the best way to track these proposals to finalization here and here. I personally skim the summary sections and then Ctrl-F the terms “remote patient monitoring” and “remote therapeutic monitoring.”

My bottom-line cheat sheet

  • RPM = physiologic, FDA-defined device, auto-uploaded data; 99453/99454 for setup/supply (watch ≥16 days), 99457/99458 for minutes with interactive communication.
  • RTM = therapeutic, non-physiologic signals (MSK, respiratory, adherence/response), allows some patient-reported inputs via device; 98975/98976/98977 (+ 98978 CBT) on the device side; 98980/98981 for minutes.
  • Do not bill RPM and RTM together for the same period; pick the right “stack” and document clearly why.
  • One practitioner per 30 days for a given monitoring stream; coordinate across specialties.
  • Audio-only is OK for management minutes, but you need real two-way interaction.

FAQ

1) Do I really need 16 days of data every month?
Answer: Only for the device supply codes that require it—99454 (RPM), 98976 and 98977 (RTM). The time-based management codes (99457/99458 and 98980/98981) don’t have the 16-day requirement. See the CMS MLN table for the exact mapping here.

2) Can I bill RPM and RTM in the same 30-day window for one patient?
Answer: No. Current guidance says you can’t bill RPM and RTM together for the same period; choose the appropriate pathway based on the signal type and document the medical necessity here.

3) Who is allowed to furnish the management minutes?
Answer: For RPM, physicians and E/M-eligible practitioners may bill, with auxiliary personnel helping under general supervision. RTM management minutes can be billed by physicians and other qualified health professionals (e.g., PT/OT/SLP) consistent with state scope. The MLN booklet outlines supervision and staff roles here.

4) Is audio-only communication enough for 99457/98980?
Answer: Yes, audio-only communication is permitted for the management minutes codes when the interaction is truly two-way and you document the content and time. This is reflected in the CMS MLN coding table and the federal remote monitoring overview here.

5) Did the codes change for 2025?
Answer: The core RPM/RTM families remain, but the AMA’s 2025 CPT code set made editorial refinements around digital therapeutics and device-supply language for RTM (98975–98978). Always confirm your payer’s current policies and the Medicare Physician Fee Schedule entries before filing here and here.

Sources & References

This blog is a personal journal and for general information only. It is not a substitute for professional medical advice, diagnosis, or treatment, and it does not create a doctor–patient relationship. Always seek the advice of a licensed clinician for questions about your health. If you may be experiencing an emergency, call your local emergency number immediately (e.g., 911 [US], 119).

```