What is CPT Code 98975?
CPT code 98975 is the billing code for initial setup and patient education in Remote Therapeutic Monitoring (RTM). It covers the onboarding process when providers configure monitoring devices like apps, wearables, or digital therapeutics. The code also includes educating patients on how to use these tools to track therapy adherence, treatment response, and health status data.
In the official CPT manual, the American Medical Association defines the 98975 cpt code description as
“Remote therapeutic monitoring (e.g., respiratory system status, musculoskeletal system status, therapy adherence, therapy response); initial setup and patient education on use of equipment.”
For a long time, providers focused on the “respiratory” or “musculoskeletal” parts of that definition. However, the phrase “therapy adherence, therapy response” is the key for behavioral health.
For mental health providers, CPT 98975 applies when setting up digital tools that monitor mood, medication adherence, cognitive behavioral therapy (CBT) exercises, or substance use recovery progress. This makes RTM a powerful revenue stream for psychiatrists, psychologists, and behavioral health practices using digital therapeutics.
The code covers the “Episode of Care,” which begins when the RTM service starts and ends when treatment goals are met. It is a one-time code per episode.
In plain terms, you’re getting paid to set up the technology and teach your patient how to use it. That’s it. The clinical work and data review come later under different codes.
One thing that trips up a lot of providers is the term “episode of care.” It simply means the period from when RTM services begin until the patient’s treatment goals are met. You can only bill 98975 once during that episode. If treatment ends and a new episode starts later, you may bill it again.
RTM vs. RPM: Why This Distinction Matters for Mental Health
RTM codes (98975 through 98981) are built for non-physiological data. That includes mood logs, therapy exercise completion, medication adherence tracking, pain scales, and behavioral patterns. Patients can self-report this data, and it still counts.
RPM codes (99453 through 99458) are designed for physiological measurements. Blood pressure. Oxygen levels. Weight. Heart rate. The data must come directly from a connected medical device; self-reporting isn’t allowed.
For mental health providers, CPT 98975 applies when setting up digital tools that monitor mood, medication adherence, cognitive behavioral therapy exercises, anxiety levels, or substance use recovery progress. This makes RTM a realistic revenue stream for psychiatrists, psychologists, and behavioral health practices already using digital therapeutics.
| Feature | RTM (98975–98981) | RPM (99453–99458) |
| Data Type | Non-physiological (mood, adherence, pain) | Physiological (blood pressure, heart rate, glucose) |
| Self-Reporting | Allowed | Not allowed |
| Mental Health Use | Ideal | Limited |
| Device Type | Apps, digital therapeutics | Connected medical devices |
| Setup Code | 98975 | 99453 |
If you submit rtm cpt codes for a depression tracking app, you are compliant. If you try to bill RPM codes for the same app, you will likely face an audit because mood is not considered physiological data under current CMS rules. That is why choosing the right code family is critical for your revenue cycle.
CPT 98975 Initial Setup: What Qualifies & What to Document
Many providers assume that simply handing a patient a device allows them to bill. This is a common mistake that leads to audits. The cpt 98975 initial setup requires more than just delivery; it requires documented education and configuration.
You need to prove that you set the tool up and that the patient actually knows how to use it. If the documentation doesn’t show active education, the payer will view it as a non-reimbursable supply cost.
What Activities Are Included in “Initial Setup”?
To bill this code correctly, your clinical staff must perform specific tasks during the onboarding visit. These are the actions that justify the reimbursement.
Your staff must complete the following:
- Configuring the device or app, such as downloading software and creating the patient account.
- Teaching the patient exactly how to log their data.
- Explaining the monitoring schedule and when they need to report.
- Setting up necessary alerts or notifications on the device.
- Answering any questions the patient has about the technology.
- Documenting the patient’s consent to participate in the program.
Patient Education Requirements
The “patient education” component of 98975 patient education is just as important as the setup. Handing over a manual isn’t enough. You need to verify understanding.
Your team must teach the patient:
- How to access the device or open the app without help.
- What specific data to record, such as mood scores, symptom severity, or medication times.
- How often they need to record this data to meet compliance rules.
- What steps to take if the device malfunctions or the app crashes.
- How their privacy and data security will be protected.
Documentation Checklist for 98975
Auditors look for specific elements in your notes. If these are missing, they can recoup the payment months later. Use this checklist to keep your 98975 setup requirements compliant.
☐ Date and time of setup session
☐ Device name/model or app name (FDA-cleared status)
☐ Specific education provided to patient/caregiver
☐ Patient demonstration of understanding
☐ Consent documented (written or verbal)
☐ Therapeutic goals for monitoring
☐ Treating provider order on file
☐ ICD-10 diagnosis code linked to RTM need
Worried about documentation gaps causing denials? Pro-MedSole RCM’s RTM billing specialists review every claim before submission. Learn about our mental health billing services →
Place of Service Considerations
Where you provide the service matters just as much as how you provide it. RTM setup rules are strict regarding location, especially for Medicare.
Here is how the Place of Service (POS) codes break down:
| Setting | POS Code | Billable? |
| Office / Clinic | 11 | ✅ Yes |
| Patient’s Home | 12 | ✅ Yes |
| Telehealth (video) | 02 | ❌ No (Medicare) |
| Telehealth (varies by payer) | Varies | ⚠️ Check commercial payers |
Under current Medicare rules, initial setup and patient education cpt code 98975 is NOT telehealth-eligible. This means the initial setup needs to happen in-person at your clinic or the patient’s home. You cannot bill this code for a Zoom setup session for Medicare patients.
However, commercial payers operate differently. Some major insurers like Anthem or Cigna may allow telehealth delivery for behavioral health setup. Always verify with the specific payer before you bill to avoid an unnecessary denial.
CPT 98975 Billing Guidelines: Rules, Frequency and Requirements
Billing 98975 correctly comes down to knowing a few key rules. Who can bill it. When you can bill it. How often you can bill it. Get these right, and you’ll avoid most of the denial practices run into with this code.
Let’s break it down piece by piece.
Who Can Bill CPT 98975?
Not every provider type qualifies for this code. CMS has specific rules about who can bill RTM services, and they differ from what you might expect based on other telehealth or monitoring codes.
Here’s the full breakdown:
| Provider Type | Can Bill 98975? | Notes |
| Physicians (MD/DO) | Yes | All specialties, including psychiatrists |
| Nurse Practitioners (NPs) | Yes | Must follow state scope of practice |
| Physician Assistants (PAs) | Yes | Must follow state scope of practice |
| Clinical Nurse Specialists (CNS) | Yes | Allowed under Medicare guidelines |
| Physical Therapists (PTs) | Yes | Requires therapy plan and GP modifier |
| Occupational Therapists (OTs) | Yes | Requires therapy plan and GO modifier |
| Speech-Language Pathologists (SLPs) | Yes | Requires therapy plan and GN modifier |
| Psychologists | Check payer | Medicare says no; some commercial payers say yes |
| LCSWs & LMFTs | Check payer | Medicare says no; some commercial payers say yes |
| Psychiatrists | Yes | As physicians under MD/DO rules |
That middle section is where mental health practices get tripped up.
Under Medicare, psychologists and licensed clinical social workers are not classified as “qualified healthcare professionals” for RTM billing purposes. That means if your practice bills Medicare for 98975 under a psychologist’s NPI, expect a denial.
Psychiatrists don’t have this problem. They’re physicians. They bill under the same rules as any MD or DO.
Here’s where it gets more nuanced. Commercial payers don’t always follow Medicare’s lead. Anthem, Optum, and some Blues plans have credentialed psychologists for RTM in certain states. The only way to know is to verify directly with each payer before you submit claims.
If your practice has a mix of psychiatrists and psychologists, this matters for workflow. The psychiatrist may need to be the billing provider for RTM services, even if a psychologist handles part of the clinical work. Structure your documentation accordingly.
The 16-Day Data Requirement
This rule catches more practices than almost anything else with RTM billing.
You cannot bill 98975 on the day you do the setup. You have to wait. The patient must actively use the RTM device for at least 16 days within a 30-day period before you can submit the claim.
Think of it this way: day one is setup and education. Days two through sixteen, the patient uses the app or device. Day seventeen or later is when you can finally bill 98975.
Here’s the timeline in simple terms:
Day 1: Setup and patient education completed
Days 2 to 16: Patient logs data using the device or app
Day 17 or later: You bill 98975
The good news is that self-reported data counts. Unlike RPM, where data has to come directly from a connected device, RTM allows patients to manually enter information. Mood logs, pain scores, medication times, exercise completion: all of it qualifies as valid data transmission.
Your billing team needs to track the first day of monitoring for each patient. Build a reminder into your workflow so claims don’t go out too early. A claim submitted on day ten will deny, and you’ll waste time resubmitting it later.
Billing Frequency Limits
CPT 98975 can only be billed once per episode of care. That’s the rule, and there’s no workaround.
An episode of care starts when RTM services begin and ends when the patient’s treatment goals are met. For a patient doing a 12-week CBT program with app-based monitoring, that entire period is one episode. You bill 98975 once at the beginning, not every month.
A new episode can start under certain conditions:
- The patient begins treatment for a new and separate condition
- There’s a significant gap between treatment periods
- A different type of monitoring device is introduced
If a patient completes treatment, stops monitoring for six months, and then restarts with a new therapeutic goal, that could justify a new episode and a new 98975 charge. But you need documentation to support it. The medical record should clearly show why this qualifies as a distinct episode.
Don’t try to bill 98975 monthly. It’s not designed for that, and payers will flag it immediately.
Modifier Requirements
Modifiers matter for 98975, especially when you’re billing it alongside other services on the same day.
Here’s what you need to know:
| Modifier | When to Use |
| 25 | Attach to the E/M code if billed on the same day as 98975 |
| 59 | Use when 98975 is a distinct and separate service from another procedure |
| GP | Required for physical therapists billing under a therapy plan |
| GO | Required for occupational therapists billing under a therapy plan |
| GN | Required for speech-language pathologists billing under a therapy plan |
| 95 | Telehealth indicator; do not use for 98975 under Medicare |
The most common scenario in mental health is billing an E/M visit on the same day as the RTM setup. If you’re doing both, append modifier 25 to the E/M code. This tells the payer that the evaluation and management service was separate and distinct from the device setup and education.
If you’re a therapist billing under a therapy plan, don’t forget the appropriate therapy modifier. Missing the GP, GO, or GN modifier is a fast path to a denial.
One more thing: modifier 95 is for telehealth services. Since 98975 isn’t telehealth-eligible under Medicare, you won’t use modifier 95 with this code for Medicare claims. Commercial payers may have different rules, but verify before assuming.
RTM billing rules are complex and constantly changing. Let Pro-MedSole RCM’s certified coders handle your mental health RTM claims so you can focus on patient care. Schedule a free consultation to see how we can help.
CPT 98975 Reimbursement Rates (2026 Update)
Let’s talk money. Providers often ask how much does 98975 pay, look at the ~$20 rate, and hesitate. It is true that CPT 98975 won’t make you rich on its own. It is a one-time setup code with modest reimbursement.
However, that small fee is the key to the castle. It unlocks the recurring monthly revenue from the RTM device supply and management codes.
Here is what you can expect from major payers in 2026 regarding the 98975 reimbursement rate:
| Payer | CPT 98975 Rate | Notes |
| Medicare National Average | $20.18 | Non-facility rate |
| Medicare (Facility) | $14.92 | Lower due to facility overhead |
| UnitedHealthcare | $19 to $23 | Varies by state contract |
| Anthem BCBS | $22 to $26 | Typically pays higher than Medicare |
| Cigna | $19 to $21 | Moderate range |
| Aetna | $18 to $22 | Depends on network tier |
| Optum Behavioral | $20 to $24 | Mental health network rates |
These numbers shift based on your geographic location. The Medicare figure comes from the national average, so your specific MAC region may pay slightly more or less.
Understanding the RVU Breakdown
If you want to know how CMS arrived at that payment, look at the Relative Value Units (RVUs). The total RVU for 98975 is 0.55.
This is split between Work RVU (0.25), Practice Expense RVU (0.29), and a tiny fraction for Malpractice (0.01). The low Work RVU reflects that this is a technical service, not a high-complexity diagnostic procedure.
Maximizing Your Reimbursement
Getting paid isn’t automatic. You need clean claims and good timing. Here is how to collect what you have earned:
Bill with the right ICD-10 codes. Every claim needs a diagnosis that supports medical necessity. For mental health, use specific Depression, Anxiety, or Substance Use Disorder codes. Do not use generic “counseling” codes.
Document medical necessity clearly. Your chart note needs to explain why the patient needs RTM. A simple sentence works: “Patient will use mood tracking app to monitor depressive symptoms between sessions to support medication adjustment.”
Submit claims promptly. Every payer has timely filing limits. Medicare gives you one year, but many commercial payers give you 90 days. If you miss the window, you write off the revenue.
Revenue Potential: A Real Example
Here is what RTM can generate for a mental health practice with 50 enrolled patients in 2026. This assumes you are billing the setup, the CBT device supply (98978), and 20 minutes of management (98980).
| Code | Description | Rate (Per Patient) | How Often | Patients | Annual Revenue |
| 98975 | Initial RTM setup | $20.18 | One time per patient | 50 | $1,009 |
| 98978 | Monthly RTM device supply | $48.12 | Monthly (12× per year) | 50 | $28,872 |
| 98980 | Monthly RTM treatment management | $51.06 | Monthly (12× per year) | 50 | $30,636 |
Total potential annual revenue: ~$60,517 from just 50 patients.
That is real money for services many practices already provide. If you use a therapy app or track symptom logs between sessions, you are doing the work. You should get paid for it.
Are you leaving RTM revenue on the table? Pro-MedSole RCM can audit your current billing and identify missed opportunities. Request your free RTM revenue analysis today →
2026 RTM Updates: The New CPT 98985 & Future Trends
RTM regulations are not static. CMS constantly tweaks these rules based on utilization data and provider feedback. For 2026, we are seeing a major shift that addresses the biggest complaint providers have: the strict 16-day requirement.
The introduction of CPT code 98985 is set to change how we handle short-term monitoring.
Solving the “16-Day” Problem
Since RTM started, the “16-day rule” has been a barrier. If a patient used their device for 15 days and then stopped, you couldn’t bill the supply code. You lost the revenue for the device supply entirely.
This was a major flaw for acute care. It created an “all or nothing” billing environment that discouraged providers from enrolling patients who might struggle with long-term compliance.
What CPT 98985 Covers (2-15 Days)
New for 2026, CPT 98985 fills that gap.
This code covers the supply of FDA-cleared devices for monitoring specifically for short-duration episodes. It allows reimbursement for data collected for just 2 to 15 days within a 30-day period.
For mental health providers, this opens doors for:
- Crisis Stabilization: Tracking high-risk patients for a week after a medication change.
- Transitional Care: Monitoring patients for 10 days after discharge from a psychiatric inpatient unit.
- Brief Episodes: Handling acute stress reactions that don’t require a full month of data.
The reimbursement for 98985 is slightly lower than the full 16-day codes, but it captures revenue you would otherwise lose completely.
Preparing Your Practice for 2026
The addition of 98985 means your billing software and workflows need to adapt. You cannot simply auto-bill code 98977 anymore. You need logic in your system that counts the days.
If the data count is 16 days or more: Bill the standard supply code.
If the data count is 2 to 15 days: Bill 98985.
Stay ahead of the curve. Pro-MedSole RCM monitors these legislative updates daily. We ensure your practice is ready for 2026 before the ball drops. Subscribe to our billing alerts →
Common CPT 98975 Billing Errors & How to Avoid Denials
Remote Therapeutic Monitoring is still fresh territory for many payers. That makes it a magnet for denials. You can do the clinical work perfectly; however, one administrative slip often stops payment cold.
We see the same rejection codes pop up repeatedly for CPT 98975. Most of these aren’t clinical failures. They are technical oversights that happen when your front office is busy or your software isn’t configured correctly.
Top 10 Reasons CPT 98975 Claims Get Denied
Here is where the revenue cycle usually breaks. This list covers the most frequent denial reasons we see in behavioral health RTM.
| # | Denial Reason | Prevention Strategy |
| 1 | Billed before 16 days of data | Wait until day 17 or later to submit |
| 2 | Missing patient consent documentation | Document patient consent clearly during setup |
| 3 | Insufficient device documentation | Record device name, model, and FDA status |
| 4 | Billing multiple times per episode | Track episode start and end dates strictly |
| 5 | Non-qualified provider billing | Verify provider eligibility by payer first |
| 6 | Missing medical necessity | Link the service to a specific ICD-10 diagnosis |
| 7 | Incorrect place of service | Use POS 11 or 12; do not use telehealth POS |
| 8 | Duplicate billing with RPM codes | RTM and RPM cannot be billed together |
| 9 | Missing treatment goals documentation | Document therapeutic objectives clearly |
| 10 | Timely filing limit exceeded | Submit claims within 90 days of service |
Documentation Audit Checklist
Auditors look for holes in the patient story. If the device isn’t FDA-cleared or the consent isn’t signed, the claim is dead on arrival.
Use this checklist as your safety net before you submit:
- Provider order on file: Ensure a physician or qualified professional ordered the service.
- Patient consent documented: This must be in the chart before the device is handed out.
- FDA-cleared device identified: The specific device name must appear in the notes.
- Education components documented: Prove you taught the patient how to use it.
- 16+ days of data collection confirmed: Count the days of transmission carefully.
- ICD-10 code supports medical necessity: The diagnosis must match the need for monitoring.
- Episode of care start date recorded: This resets your billing clock.
- No concurrent RPM billing: Check that no other remote monitoring codes are active.
Audit Risk Indicators
Getting paid is good. Getting paid too easily might be bad.
High volumes of RTM claims trigger algorithms at the payer level. They look for patterns that don’t match typical patient behavior. If you fall into these buckets, you are inviting an audit:
- Billing 98975 multiple times: You generally set up a patient once per episode.
- High volume, zero denials: This is an unusual pattern that suggests automated billing without review.
- Diagnosis Mismatch: The diagnosis codes don’t seem to require remote monitoring.
- Telehealth POS: Billing place of service “02” or “10” for setup is a major red flag.
Tired of RTM claim denials eating into your revenue?
Pro-MedSole RCM’s dedicated mental health billing team has a 98.5% clean claim rate for RTM services. We handle documentation review, claim scrubbing, denial management, and appeals so you get paid faster.
Schedule Your Free RTM Billing Consultation →
Frequently Asked Questions About CPT 98975
These are the questions we hear most often from mental health practices trying to figure out RTM billing. Straight answers, no jargon.
What is CPT code 98975 used for?
CPT 98975 pays for the initial setup and patient education when you start Remote Therapeutic Monitoring. You’re billing for the time spent configuring the app or device and teaching the patient how to use it.
For mental health, this applies to mood tracking apps, CBT platforms, medication adherence tools, and similar digital therapeutics. You can only bill it once per episode of care, and only after the patient has logged at least 16 days of data.
Who can bill CPT 98975?
Under Medicare, the following provider types can bill this code:
- Physicians, including psychiatrists
- Nurse practitioners
- Physician assistants
- Physical therapists with a therapy plan and GP modifier
- Occupational therapists with a therapy plan and GO modifier
- Speech-language pathologists with a therapy plan and GN modifier
Here’s the catch for mental health practices. Medicare does not consider psychologists or licensed clinical social workers as qualified healthcare professionals for RTM. They can’t bill 98975 under Medicare. Some commercial payers do credential these providers, so check with each payer individually.
How often can CPT 98975 be billed?
Once per episode of care. That’s it.
An episode starts when RTM services begin and ends when treatment goals are met. If the patient finishes one course of treatment and later starts a new one with different goals or a different device, that could qualify as a new episode. Document the clinical reasoning clearly if you ever bill 98975 a second time for the same patient.
What is the reimbursement for CPT 98975?
The 2026 Medicare national average is about $20.18 for non-facility settings. Facility rates run lower, around $14.92.
Commercial payers vary. Most fall between $18 and $26 depending on your contract and location. The code carries a total RVU of 0.55, which is modest. The real revenue comes from the monthly RTM codes you bill after the initial setup.
What is CPT code 98978?
This is the monthly device supply code for cognitive behavioral therapy monitoring. If your patient is using an app or digital therapeutic to track CBT exercises, mood logs, or therapy response, 98978 is how you bill for providing that tool each month.
You need at least 16 days of data within the 30-day period to bill it. For mental health practices using digital therapeutics, this is usually your primary monthly RTM code.
What is CPT code 98985?
CPT 98985 is new for 2026. It covers device supply for short-duration monitoring, specifically when patients collect data for only 2 to 15 days in a 30-day period.
Before this code existed, you got nothing if a patient fell short of 16 days. Now you can recover partial revenue. This helps with post-hospitalization monitoring, crisis stabilization, and situations where patients improve quickly and stop using the device before hitting the 16-day mark.
Can 98975 be billed via telehealth?
Not under Medicare. CPT 98975 is not on the approved telehealth list. You have to do the setup in person, either at your office or at the patient’s home. Use place of service 11 for office or 12 for home.
Some commercial payers allow telehealth delivery for behavioral health services. Anthem and Cigna have approved it in certain situations. But don’t assume coverage. Verify with the payer before you bill 98975 for any telehealth encounter.
What devices qualify for RTM under 98975?
The device has to meet the FDA’s definition of a medical device. That sounds strict, but it includes a lot of digital health tools.
Qualifying devices include smartphone apps classified as Software as a Medical Device, wearable sensors and activity trackers, digital therapeutics like reSET-O or EndeavorRx, tablet-based monitoring platforms, and biofeedback devices. For mental health, FDA-cleared CBT apps and validated mood tracking platforms count.
The key word is “FDA-cleared.” Consumer wellness apps without any regulatory status don’t qualify.
Is patient consent required for 98975?
Yes. You must document patient consent before billing any RTM code.
Consent can be written or verbal, but verbal consent needs to be noted in the chart. Cover what data you’re collecting, how it will be transmitted, and basic privacy information. CMS recommends renewing consent annually. Some commercial payers require written consent specifically, so know your payer mix.
Can RPM and RTM be billed together?
No. CMS prohibits billing Remote Patient Monitoring codes and Remote Therapeutic Monitoring codes for the same patient in the same calendar month.
RPM tracks physiological data like blood pressure and heart rate. RTM tracks non-physiological data like mood, pain levels, and therapy adherence. You have to pick one based on what you’re actually monitoring. For mental health, RTM is almost always the right choice.
Start Generating RTM Revenue in Your Mental Health Practice
CPT 98975 opens the door to recurring revenue most practices miss. The setup code pays around $20, but it unlocks monthly billing worth over $1,200 per patient annually. The 2026 updates add flexibility with the new 98985 short-duration code.
The opportunity is real. So is the complexity. Documentation requirements, provider eligibility rules, and the 16-day threshold trip up many practices. Pro-MedSole RCM specializes in mental health RTM billing. We handle setup guidance, claim scrubbing, denials, and credentialing. You focus on patients.
Schedule your free RTM billing consultation today