What Is CPT 98978? The CBT Monitoring Code Explained for Mental Health Clinicians

CPT 98978 is a Remote Therapeutic Monitoring code created by CMS that reimburses clinicians for supplying a device or software that monitors cognitive behavioral therapy response. It covers therapy adherence, mood tracking, anxiety monitoring, and behavioral health metrics collected over 16-30 days in a 30-day period. The 2026 national average reimbursement is $41.42 per patient per month. Most mental health clinicians have never heard of it.

This code is significant because it is the first CMS billing code specifically designed for digital mental health monitoring tools. It validates an entire category of software that tracks how therapy clients are doing between sessions, and it pays clinicians to use it.

What CPT 98978 Covers

The full CPT descriptor for 98978 is: "Remote therapeutic monitoring (eg, therapy adherence, therapy response, digital therapeutic intervention); device(s) supply for data access or data transmissions to support monitoring of cognitive behavioral therapy, 16-30 days in a 30-day period."

In practical terms, this code covers the supply of a device or software platform that collects data about a client's therapeutic response between visits. The data can include therapy homework adherence, mood and anxiety self-reports through digital tools, behavioral health metrics captured by wearable devices, responses to structured digital check-ins, and other non-physiological data relevant to cognitive behavioral therapy monitoring.

The code does not require the data to come from an FDA-cleared device specifically. The CPT descriptor uses the term "device(s)" which CMS has interpreted broadly to include software platforms. However, this is an area of evolving guidance and documentation of clinical rationale is important. More detail on this is in our complete RTM billing guide for therapists.

What It Pays

The 2026 national average reimbursement rates for CPT 98978:

Non-APM (most private practice therapists): $41.42 APM (accountable care organization participants): $41.63

These are national averages. Actual payment varies by geographic locality and payer. Medicare pays these rates directly. Commercial insurance adoption of RTM codes is growing but inconsistent. Check with your specific payers.

This is a monthly recurring code. If a client transmits data on 16 or more days in a 30-day period, you can bill 98978 every month the monitoring continues.

How It Fits Into the Full RTM Billing Stack

CPT 98978 is one piece of a larger billing framework. For a mental health clinician monitoring a client between sessions, a typical monthly billing scenario looks like this:

98975 (initial setup and patient education): $21.71. Billed once per episode of care when you first set up the monitoring tool and educate the client on how to use it. Requires at least 2 days of monitoring before billing.

98978 (CBT device supply, 16-30 days): $41.42. Billed monthly when the client transmits data on 16 or more days.

98980 (treatment management, first 20 minutes): $40.08. Billed monthly for time spent reviewing monitoring data, interpreting results, adjusting care plans, and communicating with the client. Requires at least one real-time interactive communication (phone or video call) during the month.

Total monthly billing per client after the first month: approximately $81.50 (98978 + 98980).

If the client transmits data on fewer than 16 days, you can use the new 2026 code 98986 ($41.42 for 2-15 days of CBT monitoring data) instead of 98978. If your treatment management time is 10-19 minutes rather than 20+, you can use the new 2026 code 98979 ($26.39) instead of 98980.

For the full code breakdown with all rates and requirements, see our complete RTM billing guide for therapists.

Why This Code Matters for Mental Health

Before CPT 98978 existed, there was no billing mechanism specifically for monitoring therapy clients between sessions using digital tools. Therapists who wanted to track client wellbeing between appointments had no way to be reimbursed for the technology or the clinical time involved in reviewing the data.

The creation of this code signals something important about the direction CMS is moving. The federal reimbursement system is now explicitly paying for continuous between-session monitoring in behavioral health. This is new. RTM codes were created in 2022. The CBT-specific code (98978) was added in 2024. In 2026, CMS expanded the framework with four additional codes including a short-window CBT monitoring code (98986) for 2-15 days. Each year, the system gets more flexible and more favorable for digital mental health monitoring.

In every other area of medicine, continuous monitoring between visits is standard practice. Cardiologists use Holter monitors. Endocrinologists use continuous glucose monitors. CPT 98978 is the beginning of that same shift in mental health.

Who Can Bill It

CPT 98978 can be billed by physicians, nurse practitioners, physician assistants, clinical psychologists, licensed clinical social workers, and other qualified healthcare professionals as defined by CMS.

The key requirements are that the provider must be operating within their state scope-of-practice laws, the monitoring must be documented under an appropriate treatment or care plan, and the provider must be the one supervising the monitoring and making clinical decisions based on the data.

For a detailed breakdown of eligibility by license type, see which license types can bill RTM.

Documentation Requirements

To bill CPT 98978, you need to document:

The clinical rationale for initiating CBT monitoring for this client. Why does this client need between-session monitoring? What clinical question is the monitoring designed to answer?

Patient consent for RTM services, including what data will be collected and how it will be used.

The monitoring device or software being used and how the client was educated on its use.

The dates of data transmission during the 30-day billing period, confirming 16 or more days of data (or 2-15 days if billing 98986 instead).

Any clinical actions taken based on the monitoring data.

For complete documentation guidance, see RTM documentation requirements for mental health.

The Revenue Opportunity

At $41.42 per client per month for the device supply code alone, and approximately $81.50 when combined with treatment management billing, RTM creates a meaningful recurring revenue stream for therapy practices.

A therapist monitoring 10 clients: approximately $815 per month in RTM revenue. A therapist monitoring 20 clients: approximately $1,630 per month. A small group practice with 3 clinicians monitoring 15 clients each: approximately $3,675 per month.

This revenue is in addition to regular session billing. For detailed revenue projections at different client counts, see our RTM revenue calculator for therapists.

Getting Started

If you are a mental health clinician and you want to start billing CPT 98978:

Verify your license type is eligible for RTM billing in your state.

Choose a monitoring platform that collects the relevant data (mood, anxiety, therapy adherence, behavioral health metrics) and generates the documentation required for clean claims.

Start with a small cohort of 5-10 clients who would clinically benefit from between-session monitoring. Clients going through medication changes, experiencing mood instability, or at elevated risk for crisis are strong candidates.

Document everything from day one. Clinical rationale, consent, data transmission dates, clinical actions taken.

Bill 98978 at the end of each 30-day period where the client has transmitted data on 16 or more days. If data transmission falls between 2 and 15 days, bill 98986 instead.

The code exists. The reimbursement is real. The question is whether your practice is set up to capture it.