CPT Code 98980: RTM billing, time rules, and reimbursement

Key Takeaways

CPT Code 98980 covers the first 20 minutes of Remote Therapeutic Monitoring (RTM) treatment management per calendar month, requiring at least one interactive communication with the patient or caregiver.

Physical therapists, occupational therapists, and speech-language pathologists can independently bill 98980 under Medicare without physician supervision, per the CMS 2022 Final Rule.

98980 and 99457 (RPM treatment management) cannot be billed together for the same patient in the same calendar month, per the AMA 2022 CPT Manual.

Pabau’s claims management software and automated billing workflows help physical therapy and occupational therapy practices track RTM time, document interactive communications, and submit 98980 claims accurately.

CPT Code 98980 is the primary treatment management code in the Remote Therapeutic Monitoring (RTM) family, covering the first 20 minutes of qualified clinician time spent managing a patient’s non-physiological data in a calendar month. Payers commonly deny claims for avoidable reasons. These include missing interactive communication documentation, time tracked against the wrong calendar month, and uncertainty about who can independently bill the code.

This guide covers the billing rules, time requirements, documentation standards, reimbursement rates, and common errors for CPT Code 98980.

CPT Code 98980: definition and clinical scope

The American Medical Association (AMA) defines CPT Code 98980 as: “Remote therapeutic monitoring treatment management services, physician/other qualified health care professional time in a calendar month requiring at least one interactive communication with the patient/caregiver during the calendar month; first 20 minutes.”

Non-physiological data includes musculoskeletal function (range of motion, pain, activity levels) and respiratory system function. RTM covers non-physiological data. RPM covers physiological data such as blood pressure and blood glucose. For physical therapy practices and rehabilitation clinics, 98980 is the code that captures the clinical management time spent reviewing that remotely collected musculoskeletal data.

The code was introduced in January 2022 as part of the CMS Final Rule establishing the RTM code family. It compensates clinicians for reviewing patient progress data and communicating between visits. Before 2022, no billing mechanism existed for this work.

The RTM code family: where 98980 fits

CPT Code 98980 belongs to a five-code RTM family. Using 98980 without the correct supporting supply codes creates incomplete claims; billing the wrong add-on sequence leads to denials.

Practices running occupational therapy programs or musculoskeletal rehabilitation typically bill 98975 once at the start of an RTM episode, bill 98976 monthly for device supply, and then bill 98980 (and 98981 where time warrants) for each calendar month of active management. Getting the sequence right matters: practices must report 98975 before billing 98980.

Note that the 16-day data transmission requirement that applies to some device supply codes does not apply to 98980 or 98981. According to HHS Telehealth guidance, the 16-day threshold applies to monitoring device supply codes, not to treatment management codes. This is a common misunderstanding that causes practices to undercount billable months.

Time requirements and eligible billing providers for CPT 98980

Two requirements must be met before CPT Code 98980 can be billed for a calendar month.

The 20-minute threshold

The billing clinician must accumulate a minimum of 20 minutes of RTM management time within the calendar month. This includes reviewing patient-reported data, interpreting musculoskeletal or respiratory metrics, adjusting care plans, and communicating with the patient or caregiver. It does not include time spent on separate in-person visits.

Time can be accumulated across multiple shorter sessions throughout the month. For example, 12 minutes reviewing data on day 8 and 10 minutes communicating with the patient on day 22 meets the threshold. The APTA Practice Advisory confirms that the 20-minute clock resets with each new calendar month, not on a rolling 30-day basis.

The interactive communication requirement

At least one interactive communication with the patient or their caregiver must occur during the calendar month. Interactive means real-time, synchronous contact: a phone call, a video consultation, or an in-person exchange specifically related to the RTM data.

Asynchronous messaging alone does not satisfy this requirement. A clinician who spends 25 minutes reviewing data and exchanging secure messages — but never has a synchronous conversation — cannot bill 98980 for that month. A telehealth platform for RTM check-ins helps meet this requirement efficiently. It also captures a timestamped record of the interaction for audit purposes.

Eligible billing providers

Under the 2022 CMS Final Rule, the following provider types can bill 98980 independently under Medicare:

• Physicians (MD, DO)
• Nurse Practitioners (NP)
• Physician Assistants (PA)
• Physical Therapists (PT)
• Occupational Therapists (OT)
• Speech-Language Pathologists (SLP)
• Qualified Allied Health Professionals acting within their scope of practice

Physical therapists and occupational therapists can bill 98980 without physician supervision under Medicare, a significant expansion from earlier RPM rules. For speech-language pathology practices, the same independent billing right applies. Practices managing complex diagnosis coding alongside RTM may also find it useful to review ICD-10 Code F59 for unspecified behavioral syndromes or ICD-10 code M45.2 for ankylosing spondylitis of the cervical region when documenting RTM conditions. Incident-to billing rules under Medicare do not apply to 98980 when billed by PTs, OTs, or SLPs. Practices should verify commercial payer rules per contract.

Documentation requirements for CPT 98980 compliance

Claim denials and audit exposure for 98980 share a common root: documentation that cannot prove both the time threshold and the interactive communication requirement were met.

What to capture in the patient record

Every 98980 claim should be supported by a contemporaneous note. This note must include the date(s) time was accumulated, the total cumulative time for the calendar month, a description of clinical activities performed, the date and method of the interactive communication, and the clinical rationale connecting the RTM data to the care decision.

Digital intake and consent forms at RTM enrollment ensure patients have provided documented consent before the first data transmission. The adult informed consent form template can be adapted for RTM programs. Auditors frequently flag missing consent documentation in RTM programs.

For physical therapy compliance, the documentation standard for 98980 aligns with general medical necessity requirements. The record must show that a qualified clinician reviewed specific patient data and made a clinical decision — not simply that time passed.

Centralized patient records for RTM

When time is tracked in spreadsheets, individual clinician notes, or disconnected systems, practices frequently miss the 20-minute threshold at month-end and never submit the claims. A centralized patient record management system that logs RTM time against individual patient accounts makes the accumulated total visible in real time.

Stop losing RTM revenue to missed claims

Pabau helps physical therapy and occupational therapy practices track RTM time per patient, document interactive communications, and submit 98980 claims without manual spreadsheet tracking.

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CPT 98980 vs 98981: billing the add-on code

CPT Code 98981 is the add-on code for RTM treatment management. It covers each additional full 20-minute unit of clinician time beyond the first 20 minutes already captured by 98980.

How 98981 works in practice

Practices cannot bill 98981 without also reporting 98980 in the same calendar month. Always bill it alongside the base code, not independently. The billing sequence looks like this:

• 20-39 minutes total: Bill 98980 only (one unit)
• 40-59 minutes total: Bill 98980 + one unit of 98981
• 60+ minutes total: Bill 98980 + two units of 98981

A critical distinction: the midpoint rule does not apply to 98981. Each unit of 98981 requires a full additional 20 minutes of qualifying time. A clinician who accumulates 35 minutes bills one unit of 98980. At 39 minutes, they still bill only one unit of 98980. The second code triggers only when a complete additional 20-minute block has been reached.

98980 vs 99457: the mutual exclusivity rule

CPT Code 99457 is the RPM (Remote Patient Monitoring) treatment management equivalent for physiological data. The AMA 2022 CPT Manual states explicitly that 98980 should not be reported in conjunction with 99457 for the same patient in the same calendar month.

The practical reason: RTM and RPM are designed for distinct data types. A patient monitored for both musculoskeletal outcomes (RTM) and blood pressure (RPM) might appear to warrant both code sets. However, CPT parenthetical instructions and CMS NCCI edits restrict concurrent billing in the same calendar month. Practices managing patients with overlapping monitoring needs should consult with their billing specialist or coding advisor before billing both codes in the same month. The CMS Physician Fee Schedule is the definitive source for checking current payment rules and any code-pair edits for 98980.

CPT 98980 reimbursement rates

Medicare reimbursement for CPT Code 98980 varies by geographic location. CMS updates it annually through the Medicare Physician Fee Schedule (MPFS). CMS expresses rates in relative value units (RVUs) and converts them to dollar amounts using its annual conversion factor.

For current verified rates, use the CMS Physician Fee Schedule search tool to look up 98980 by code for your specific locality. Rates for 2025 and 2026 reflect the ongoing CMS payment adjustments to telehealth and remote monitoring codes.

Commercial payer coverage for 98980 varies significantly. Some major payers have adopted Medicare’s RTM framework; others have not yet issued coverage determinations for the RTM code family. Verifying payer-by-payer coverage before enrolling patients in an RTM program prevents claim submissions that will never be covered.

State Medicaid programs have varying adoption rates for RTM codes. As of 2025, Medicare is the most reliable reimbursement pathway for 98980. Commercial payer coverage is expanding but remains inconsistent across states and plans.

Common CPT 98980 billing mistakes

Payers deny RTM claims for 98980 for predictable, preventable reasons. The following error patterns account for the majority of rejections.

Missing or incomplete time documentation

The most common denial reason: the clinical record does not document how the 20-minute threshold was reached. A billing entry that says “RTM review performed” without specifying the time spent, dates, and activities does not support the claim. Each session contributing to the 20-minute total needs its own dated entry in the patient record. Automated billing workflows prompt clinicians to log time at the close of each RTM interaction. This reduces errors without adding manual steps to the end-of-day workflow. For practices also submitting preventive care claims, see the billing guide for CPT Code 80307 presumptive drug testing as a related compliance reference.

Asynchronous-only communication billed as interactive

Secure messaging platforms are useful for RTM programs. However, a month where the only patient contact was asynchronous messages does not meet the interactive communication requirement. Payers will deny claims without a documented synchronous interaction on audit. Build a monthly touchpoint into the RTM workflow. A brief check-in call logged with the date, duration, and communication method satisfies the requirement and provides the audit trail.

Calendar month vs rolling 30-day confusion

98980 is billed per calendar month, not per rolling 30-day period. A patient enrolled on January 15 generates a separate billable calendar month for January and another for February, even though fewer than 30 days separate them. Practices tracking RTM on a 30-day-from-enrollment basis systematically miss the month-boundary billing opportunity. For physical therapy practices with large RTM panels, this error compounds across hundreds of patients annually.

Billing 98980 without the prerequisite setup code

CPT Code 98975 (initial setup and patient education) must be reported before 98980 can be billed for any episode of care. Skipping 98975 because it has a lower reimbursement value than 98980 creates a billing sequence that payers flag as a compliance error. Bill 98975 once at the start of each RTM episode, then bill 98980 monthly. Claims management software that enforces billing sequence rules prevents this error at the point of submission — before a denial is issued.

Conclusion

Accurate billing of CPT Code 98980 requires four things: 20 minutes of qualified clinician time, one synchronous patient interaction, contemporaneous documentation, and the correct billing sequence within the calendar month. Practices that systemize these requirements rather than managing them manually submit cleaner claims and capture more RTM revenue.

Related codes in the broader monitoring space include HCPCS Code A9278 for external CGM receiver billing and home-based care codes such as CPT code 99347 for home visits with established patients. For practices also managing preventive care, see CPT code 99383 for preventive medicine visits.

Pabau’s claims management software helps physical therapy, occupational therapy, and allied health practices track RTM time per patient, document interactive communications, and flag billing sequence errors before submission. To see how Pabau handles RTM billing workflows, book a demo.

Continue your research

Running a physical therapy practice and need RTM billing support? Physical therapy EMR software built for rehabilitation practices, with clinical documentation and billing workflow tools.

Managing occupational therapy patients on RTM programs? Occupational therapy software with features designed for OT-specific documentation and compliance requirements.

Need to track time, outcomes, and RTM data in one place? Patient measurements and outcomes tracking in Pabau connects clinical data collection to billing workflows for RTM programs.

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