Remote Therapeutic Monitoring for Therapists: A Practical Guide to RTM Billing in 2026

Most therapists have never heard of these billing codes. They could add $100-200 per patient per month to your practice revenue.

We talk to therapists every day. When we mention that CMS has created billing codes specifically for monitoring clients between sessions using software and wearable devices, the reaction is almost always the same: "Wait, what? That exists?"

It does. Since 2022, the Centers for Medicare and Medicaid Services has been building out a reimbursement framework called Remote Therapeutic Monitoring (RTM) that pays clinicians to do exactly what most therapists wish they could do: keep track of how clients are doing between appointments. In 2024, CMS added a code specifically for cognitive behavioral therapy monitoring. In 2026, they expanded the framework again with four new codes and increased reimbursement rates. Here is what the codes are, how the billing works, what the requirements are, and what the realistic revenue opportunity looks like for a therapy practice.

What Is Remote Therapeutic Monitoring

RTM is a category of CPT billing codes that reimburse clinicians for using devices and software to continuously monitor patient therapeutic response between clinical visits. It is distinct from Remote Patient Monitoring (RPM), which focuses on physiological vital signs like blood pressure and blood glucose. RTM covers non-physiological data: therapy adherence, patient-reported outcomes, cognitive and behavioral health metrics, and therapeutic response tracking.

The distinction matters because RTM is explicitly designed for the kinds of data therapists work with. It is not repurposed cardiology billing. It was built for therapy, rehabilitation, and behavioral health from the ground up.

CMS created the first RTM codes in the 2022 Physician Fee Schedule. The code set has expanded in every subsequent year, which tells you something about the direction CMS is moving.

The Complete RTM Code Set for 2026

Here is every RTM CPT code currently active, with the 2026 national average reimbursement rates for non-facility settings.

98975: Initial Setup and Patient Education What it covers: Setting up the RTM device or software for the patient, educating them on how to use it, and enrolling them in the monitoring program. When to bill: Once per episode of care. An episode begins when RTM services start and ends when treatment goals are met. Requirement: At least 2 days of monitoring must occur before this code can be billed. 2026 reimbursement: $21.71

98977: Device Supply, Musculoskeletal System (16-30 days) What it covers: Supplying the monitoring device or software for musculoskeletal therapy monitoring over a period of 16 to 30 days in a calendar month. When to bill: Once per 30-day period when 16 or more days of data have been transmitted. 2026 reimbursement: $41.42

98978: Device Supply, Cognitive Behavioral Therapy (16-30 days) What it covers: Supplying the monitoring device or software specifically for cognitive behavioral therapy monitoring. This is the code most directly relevant to mental health. It covers software that monitors mood, anxiety, therapy adherence, and behavioral health metrics. When to bill: Once per 30-day period when 16 or more days of data have been transmitted. 2026 reimbursement: $41.42

98976: Device Supply, Respiratory System (16-30 days) What it covers: Respiratory system therapeutic monitoring. 2026 reimbursement: $41.42

98985: Device Supply, Musculoskeletal System (2-15 days) [NEW FOR 2026] What it covers: Same as 98977 but for shorter monitoring windows. When to bill: Once per 30-day period when 2-15 days of data have been transmitted. Cannot be billed in the same month as 98977. 2026 reimbursement: $41.42

98984: Device Supply, Respiratory System (2-15 days) [NEW FOR 2026] What it covers: Respiratory monitoring for shorter windows. 2026 reimbursement: $41.42

98986: Device Supply, Cognitive Behavioral Therapy (2-15 days) [NEW FOR 2026] What it covers: Same as 98978 but for shorter monitoring windows. For mental health providers, this is significant. You can now bill for CBT monitoring even when you only have 2-15 days of data in a month, which covers partial months, new enrollments, and transitions. 2026 reimbursement: $41.42

98980: Treatment Management Services (first 20 minutes) What it covers: Provider time spent reviewing RTM data, interpreting results, adjusting care plans, and communicating with the patient about their monitoring data. Requires at least one real-time interactive communication (phone or video call) with the patient during the calendar month. When to bill: Once per calendar month for 20+ minutes of treatment management time. 2026 reimbursement: $40.08

98979: Treatment Management Services (first 10 minutes) [NEW FOR 2026] What it covers: Same as 98980 but for 10-19 minutes of provider time. Previously, the minimum was 20 minutes. This new code captures the realistic scenario where a therapist spends 10-15 minutes reviewing data and making a brief call. When to bill: Once per calendar month for 10-19 minutes. Cannot be billed in the same month as 98980. 2026 reimbursement: $26.39

98981: Treatment Management Services (each additional 20 minutes) What it covers: Additional 20-minute increments of treatment management beyond the initial 20 minutes billed under 98980. When to bill: Can be billed once per calendar month in addition to 98980. 2026 reimbursement: $33.57

What This Looks Like in Practice for a Therapist

Here is a realistic monthly scenario for a therapist monitoring a single client.

The client wears a wearable device. A monitoring platform collects their sleep data, heart rate variability, activity levels, and conducts daily AI check-ins. The therapist reviews the dashboard data before each session and has one brief phone check-in with the client during the month (fulfilling the interactive communication requirement).

Billable codes for that month:

98975: $21.71 (first month only, setup) 98978: $41.42 (CBT device supply, 16+ days of data) 98980: $40.08 (20+ minutes of treatment management)

Monthly recurring revenue per client (after first month): $81.50

If you are monitoring 15 clients and 12 of them transmit 16+ days of data:

Monthly RTM revenue: approximately $978

At 20 clients with similar compliance: approximately $1,630 per month.

That is in addition to your regular session billing.

Requirements and Compliance

These are the rules you need to follow.

Who can bill: Physicians, nurse practitioners, physician assistants, clinical psychologists, licensed clinical social workers, physical therapists, occupational therapists, and speech-language pathologists. Billing must be under appropriate state scope-of-practice laws.

Patient consent: Written or verbal consent must be documented before initiating RTM services. The patient must understand what data is being collected and how it will be used.

Data transmission minimum: For the 16-30 day codes (98977, 98978, 98976), the patient must transmit data on at least 16 days within a 30-day period. For the new 2-15 day codes (98984, 98985, 98986), 2-15 days of data transmission are required.

Interactive communication requirement: Codes 98979, 98980, and 98981 require at least one real-time interactive communication with the patient during the calendar month. CMS defines this as "at a minimum, a real-time synchronous, two-way audio interaction that is capable of being enhanced with video or other kinds of data transmission." In practice, this means a phone call or video call. Text messaging and asynchronous chat do not currently qualify on their own, though CMS has indicated it will adopt whatever definition the 2026 CPT Manual provides for "interactive communication."

One provider per patient per month: Only one clinician can bill RTM codes for a given patient in a 30-day period. The first provider to submit the claim is reimbursed. Subsequent claims will be denied.

RPM and RTM cannot be billed together: You cannot bill both Remote Patient Monitoring and Remote Therapeutic Monitoring for the same patient in the same month.

Documentation: You need to document the clinical rationale for RTM, the patient's consent, the data collection period, the number of active monitoring days, any clinical interventions triggered by the data, and the time spent on treatment management activities.

The FDA Clearance Question

This is the most common concern therapists raise, and it deserves a direct answer.

Consumer wearable devices do not have FDA clearance as medical devices for mental health monitoring. Features like ECG and blood oxygen on some devices have specific FDA clearances, but sleep tracking, HRV measurement, and activity tracking are classified as general wellness features.

CPT 98978 specifies monitoring via a "medical device" for cognitive behavioral therapy. CMS has not published definitive guidance on whether consumer wearable data transmitted through a clinical software platform satisfies this requirement.

In practice, the landscape is moving quickly. The Empatica EmbracePlus wrist-worn device does have FDA clearance (K221282, K230457, K242737) for physiological monitoring and is specifically designed for clinical and research applications. Platforms that aggregate consumer wearable data through clinical software layers are increasingly positioning themselves as the "device" for billing purposes.

The conservative approach: bill RTM codes using an FDA-cleared device like Empatica and treat consumer wearable data as supplementary clinical information.

The pragmatic approach: bill using clinical software that ingests wearable device data, document the clinical rationale thoroughly, and be prepared for some claim denials (estimated 20-30% denial rate in behavioral health RTM currently) while the regulatory landscape settles.

The long-term trajectory: CMS has been expanding RTM codes every year since 2022. The direction is clearly toward broader adoption and more flexible device requirements, not narrower ones.

What RTM Means for the Therapy Business Model

RTM does not change what you do clinically. It changes how you get paid for something you probably already want to do: monitor your clients between sessions.

Most therapists describe the same frustration. They know a weekly session is not enough visibility into a client's condition. They know things happen between appointments that they never find out about. They know sleep and stress and medication changes affect treatment but they have no way to track them. RTM creates a billing framework for closing that 167-hour blind spot.

The financial case is straightforward. A therapist monitoring 15-20 clients through a platform like Reyma can generate $1,000-1,600 per month in RTM revenue. If the platform subscription costs $500 per month, the RTM revenue alone more than covers the cost of the tool. The clinical intelligence (session prep briefs, risk alerts, biometric trends) comes effectively free.

Getting Started

If you are a licensed therapist in private practice and you want to explore RTM billing:

First, verify your state scope-of-practice laws allow RTM billing for your license type. Most states allow it for LCSWs, PhDs, PsyDs, LMFTs, and LPCs, but requirements vary.

Second, check your payer mix. RTM codes are Medicare codes. Medicare reimburses them directly. Commercial payer adoption is growing but inconsistent. Some commercial insurers reimburse RTM codes at Medicare rates or higher. Others do not yet cover them.

Third, choose a monitoring platform that handles data collection, clinical interpretation, and documentation. The platform should generate the RTM compliance documentation you need for billing: date ranges, monitoring days, data summaries, clinical review records, and intervention logs.

Fourth, start with a small cohort. Enroll 5-10 clients who already wear a wearable device and who would clinically benefit from between-session monitoring (medication changes, mood instability, sleep issues, crisis risk). Run it for 60-90 days. See what the data tells you, see how it changes your sessions, and see what your claim acceptance rate looks like.

The billing codes exist. The technology exists. The clinical value is demonstrable. The only question is implementation.