RTM software (remote therapeutic monitoring)

What remote therapeutic monitoring is

CMS defines RTM next to its sibling, remote physiologic monitoring (RPM). RPM monitors physiologic metrics: blood pressure, weight, glucose, oxygen saturation. RTM captures non-physiologic data related to a therapeutic treatment, which can be self-reported, covering the patient’s respiratory or musculoskeletal system, and it can monitor adherence to the treatment and response to it. A connected medical device transmits the data.

Three things follow.

• The device has to be a medical device under FDA’s definition. A PAP machine with a built-in modem qualifies. A spreadsheet of patient-reported hours does not.
• The data is about the therapy, not the body. Hours of PAP use per night is RTM data. The patient’s blood pressure is RPM data.
• RTM does not require an established patient relationship. RPM does. A sleep practice can start RTM on the day the device is set up.

Physicians and the non-physician practitioners who are eligible to bill evaluation and management services bill RTM. Auxiliary personnel can furnish the monitoring under the billing practitioner’s general supervision. One practitioner bills for a given patient in a 30-day period, the patient consents before the service begins, and the monitoring has to be medically reasonable and necessary.

In practice RTM shows up in three places: PAP adherence in sleep medicine and pulmonology, home exercise and activity adherence in physical therapy and orthopedics, and engagement with digital cognitive behavioral therapy in behavioral health. The code set has a device family for each.

The 2026 RTM code set

Payment figures are the CY2026 national non-facility amounts, from CMS’s relative value file and the 2026 conversion factor of $33.40. Your locality will differ.

The device-supply logic. Each body system now has two device codes, one for 16 to 30 days of data in the 30-day period and one for 2 to 15 days. They are not a base and an add-on. CMS is explicit that they are not additive: a practitioner bills one of them per 30 days, whichever matches the number of days the device transmitted data. Before 2026 there was no device-supply code for a period with fewer than sixteen days of data. Now there is, at the same national amount as the 16-day code for the respiratory and musculoskeletal families.

The count is days of data transmission. It is not days of good adherence. A PAP machine that reports every night but runs for an hour has thirty days of data. That distinction matters most in sleep medicine, and the CPAP compliance page works through it.

The treatment-management logic. 98980 pays for the first twenty minutes in a calendar month of a practitioner’s or clinical staff’s time managing the treatment, and it requires at least one interactive communication with the patient or caregiver in that month. 98981 adds each further twenty minutes. The new 98979 pays for a month with only ten minutes, and it replaces 98980 in that month rather than adding to it.

Note the two clocks. Device-supply codes run on 30-day periods from the day monitoring began. Treatment-management codes run on calendar months. Software that tracks one clock and assumes the other produces claims that do not match the record.

Setup is 98975, once per episode of care, covering the patient education and the initial device configuration.

Rural health clinics and FQHCs bill these codes individually; the G0511 bundle ended on 30 September 2025. One caveat carried over from the 2026 code guide: the amounts for 98976 and 98977 were corrected by CMS in March 2026, and CMS’s separate RHC and FQHC rate table, dated June 2026, still prints the earlier figures. If a contract depends on them, confirm with your Medicare Administrative Contractor.

RTM and RPM are not the same program

Either one can run alongside chronic care management, principal care management, transitional care management or behavioral health integration for the same patient, provided no minute is counted twice. The code guide has the full table of what can and cannot be billed together, and what is chronic care management? covers the CCM side.

What RTM software has to do

Strip the marketing off and there are four jobs.

1. Device data, counted correctly. The software has to receive the data from wherever the device platform puts it, attribute each day to a patient and a 30-day period, and keep a running count of transmission days per period. It also has to keep the therapy measure itself, the hours per night or the sessions per week, because that is what the clinician is managing. Two counts, per patient, per period, visible before the period closes. If the count is only visible at month end, the practice cannot intervene while intervention still changes the number.

The honest question for any vendor is which device platforms it connects to and by what path: a direct feed, a file export, or a report somebody uploads. All three can work. Only the first is automatic.

2. Patient outreach that leaves a record. 98980 requires an interactive communication in the month. Patients whose devices stop reporting need to be reached within a day, not at the next visit. Both need consent on file, a check against the patient’s contact preferences before every message, and a written record of what was said and when. Outreach that lives in a coordinator’s phone does not exist for audit purposes.

3. Time capture, by the person spending it. The treatment-management codes pay for a person’s minutes. The software’s minutes are not billable, and neither are minutes typed in from memory on the last day of the month. Time should be logged as it is spent, against the patient, by the person who spent it, with a timestamp.

4. Monthly billing readiness. A gate, per patient, per period, that checks every element before anyone sees a claim: consent documented, setup billed once, days of data in the period, the interactive communication in the month, the minutes threshold, one practitioner in the period, no RPM for the same patient. Patients who clear it go to the biller. Patients who do not carry a hold reason. A person releases each one. Nothing auto-bills.

Everything else, dashboards, reports, patient apps, is presentation. Those four are the product.

How Caesar Health runs RTM

Caesar is not an RTM point product. It is an operating layer on the EMR you already run, a clinic operating system, and RTM is one of the programs its engine runs, alongside chronic care management, principal care management and APCM. The same monthly cycle, the same review queue and the same billing gate, with RTM’s rules loaded instead of CCM’s.

Each patient in an RTM program is a case the engine carries through the month. The period opens, the device days are counted, patients are sorted into the buckets you define (on track, slipping, no data, device problem), and the outreach to the slipping and silent patients runs by SMS or phone in your approved wording. The agent drafts the monthly note and the patient message. A person on your team reviews, approves, and logs the minutes as they are spent. The billing gate checks the elements above and holds anyone who does not clear. A person sets Ready for Billing.

What the agent does is the logistics: the chasing, the counting, the drafting, the reminding. What your staff do is the treatment management, and the system evidences their minutes rather than replacing them.

Here is the line between what runs today and what does not.

Device readings reach the program today through the reports your device platform already produces. When the direct connections ship, the import swaps and nothing downstream changes.

Start a pilot with one RTM panel. We run one monthly cycle end to end, in your EMR, with your staff on the review queue, and you read the billing gate at the end of it.

A vendor-neutral checklist

Ask any RTM vendor, including us, these questions. Written answers.

1. Which device platforms feed the software, and by which path for each: direct feed, file export, or uploaded report?
2. Can you see, per patient, the count of transmission days in the current 30-day period before it closes?
3. Does it keep the 30-day device period and the calendar month for treatment management as two separate clocks?
4. Where is the interactive communication for 98980 recorded, and is its date visible on the billing-readiness view?
5. Is time logged as it is spent, by the person spending it, with a timestamp? Ask to see the log.
6. Does any of the software’s own activity get counted toward the minutes? If the answer is yes, that is a claim an auditor will not accept.
7. Is consent captured with a timestamp and checked before every outbound message?
8. Which elements does the billing gate check, and does a person release each patient?
9. Does the monthly note go into the EMR, or does it live in the vendor’s portal?
10. Can an auditor reproduce any patient’s month: what triggered each action, what data was read, which rule applied, who approved?
11. Is a Business Associate Agreement signed at contract, and what is the vendor’s SOC 2 status, stated plainly?