Building RTM Infrastructure That Aligns With CMS Billing and Documentation Rules
Remote Therapeutic Monitoring has grown from a small to a major income engine. Many platforms still fall short of CMS criteria, resulting in claim rejections and audit risk. When your RTM platform gathers data but fails to comply with CMS billing standards, claim denials can accumulate.
Rejecting CPT 98980 or 98981 reduces margins, undermines provider trust, and triggers audits that reveal compliance problems.
In this blog, you’ll know how to integrate FDA-grade devices, 16-day counters, and automatic 20-minute records into an RTM stack that passes CMS inspection and ensures timely payment without exhausting engineering hours or budgets.
2025 RTM Billing
| CPT Code | What It Pays for | Key 2025 Requirement | Avg. Non-Facility Rate |
| 98975 | Initial device set‑up & patient education | ≥ 16 days of data in 30 days | $19.73 |
| 98976 | Resp. device supply & transmission | ≥ 16 days/30 days | $43.02 |
| 98977 | MSK device supply & transmission | ≥ 16 days/30 days | $43.02 |
| 98978 | CBT digital‑therapy device | 16‑day rule waived | Refer PFS |
| 98980 | First 20 min. Treatment mgmt. | ≥ 1 interactive contact | $50.14 |
| 98981 | +Each add’l 20 min. | Same as 98980 | $39.14 |
New for 2025
- Individual RTM CPT codes can be billed by FQHCs and RHCs commencing January 1st, with G0511 due to expire on July 1st, 2025.
- Audio-only appointments are chargeable until September 30, 2025, making them useful for patients who do not have access to video.
- PT/OT assistants in private practice may work under broad rather than direct supervision, reducing staffing friction.
CMS Compliance Requirements
1. Device Integrity
- The device must comply with the FDA’s “medical device” definition and securely transfer data.
- RTM enables patient-reported data and self-entry user processes, including device uploads.
2. 16-Day Data Rule
- Codes 98975-98977 need at least 16 days of readings during a 30-day episode. Validate claims automatically before they are created.
3. Interactive Communication Logging
- 98980/98981 requires 20 minutes of care-manager time each month, including at least one real-time engagement like phone, video, or chat. Each touch should be timestamped and classified.
4. Mutually Exclusive Billing Logic
- Block RTM claims for RPM codes 99453-99458 that already exist in the same period.
5. One-Provider Rule
- The first to file wins, and all later RTM/RPM claims for that patient episode are refused. Deduplicate NPI numbers.
Three Components of a CMS-Ready RTM Stack
1. Data Capture & Device Layer
- FDA-cleared endpoints for respiratory, musculoskeletal, and CBT use cases.
- Automatic encryption, fault recovery, and device identity management.
- Validation checks for patient-reported inputs such as pain levels and medication adherence.
2. Clinical Workflow & Middleware
- The rules engine evaluates 16-day and 20-minute criteria in real time.
- The dashboard alerts patients about potential non-compliance.
- Secure texting and planned video calls automatically record interaction minutes.
3. Billing and Documentation Engine
- Identify and eliminate duplicate claims by cross-referencing CPT logic such as RTM, RPM, and CCM.
- Include electronic consents and plan-of-care signatures, and apply the 2025 therapist signature exception rationale when applicable.
- Create audit-ready PDF packets with one click, including device logs, encounter transcripts, and supervisory attestations.
12‑Week Implementation Roadmap
| Week | Milestone | Outcome |
| 0-2 | Gap Assessment | Map current state vs CMS rules |
| 3-4 | Device & Data Layer Hardening | FDA‑grade encryption, 16‑day counters |
| 5-6 | Middleware Rule Engine | Real‑time compliance alerts |
| 7-8 | EHR & RCM Integration | HL7/FHIR feeds, claim scrubbing |
| 9-10 | Pilot with 5 Clinicians | Validate billing accuracy, gather UX feedback |
| 11-12 | Full Launch & Audit Drill | Simulate CMS probe & educate staff |
Metrics that Demonstrate Compliance and ROI
- First-pass payout rate for RTM claims
- The percentage of claims with comprehensive 16-day documentation
- Average days till clinician sign-off
- Audit finding rate per thousand claims
- Patient adherence, like device days/prescribed days
Common Pitfalls – and How to Avoid Them
- Mixing RTM and RPM codes for the same patient block at the claim edit level.
- Automatically start timers when the staff opens the patient chat to avoid missing interactive minutes of evidence.
- Non‑qualified devices, maintain the FDA device register, and execute nightly compliance checks.
- Duplicate billing across groups using NPI-level deduplication and payer eligibility pings.
Documentation Best Practices for CMS Audits
- Device Serial + FDA. Every claim includes a listing.
- Time-stamped communication records for 98980/98981 minutes.
- Episode-level confirmation that RTM was not paid concurrently with RPM or by another supplier.
- Link the plan of care to the claim details, including the therapist’s treatment plan and any documented exceptions.
- Consent artifacts are preserved for 10 years.
Related: RTM Essentials: A Practical Guide for PT, OT, and SLP
Turn RTM Compliance Into Profit with CapMinds
CapMinds turns complex CMS rules into clean, first-pass payments.
Our end-to-end digital health tech stack lets you deploy a compliant RTM program in weeks, not months, while freeing your team to focus on care, not paperwork.
- RTM Device Onboarding & FDA-grade Data Capture
- Middleware Rule Engine with real-time 16-day and 20-minute counters
- HL7/FHIR & EHR Integration for seamless clinical workflows
- Automated CMS Billing, Claim Scrubbing, and NPI Deduplication
- One-click Documentation Packets for audit-ready evidence
From gap assessments to full launch, our experts align every pixel with 2025 CPT logic, therapist signature exceptions, and audio-only billing windows.
You gain higher first-pass payout rates, fewer denials, and dashboards that prove ROI.
Let CapMinds architect your RTM, RPM, and CCM programs so you stay ahead of CMS changes and your competitors.
Book a free strategy call now and watch compliant revenue flow tomorrow.
