TL;DR

The RTM clinician workflow is the structured, repeating cycle that therapists follow to deliver and bill for Remote Therapeutic Monitoring: enroll the patient, collect remote data, review and act on that data, document everything, and bill the correct CPT codes. The 2026 CMS updates introduced lower thresholds (2 days of data and 10 minutes of management time), making the workflow accessible to far more practices. Getting the workflow right is primarily a documentation challenge, not a coding one.

The RTM clinician workflow is the end to end process a therapist follows each month to set up, monitor, review, document, and bill Remote Therapeutic Monitoring services. It applies to physical therapists, occupational therapists, and speech language pathologists who treat patients with musculoskeletal, respiratory, or neuromuscular conditions and want to extend care between visits.

RTM is not telehealth. It is not a video visit. It is not asking patients to text you updates. It is a CMS reimbursed program that uses FDA cleared digital tools to track therapy adherence, pain levels, and functional progress at home, and then pays clinicians for the clinical time spent reviewing and acting on that data.

One quick distinction: Remote Therapeutic Monitoring (RTM) tracks therapy related data like exercise adherence and pain scores. Remote Physiologic Monitoring (RPM) tracks vital signs like blood pressure and oxygen saturation. Different data, different codes, different workflow.

See RTM ready plans and pricing

The 5 Phases of the RTM Clinician Workflow

Every RTM clinician workflow follows the same five phases. Each phase maps to specific actions and, in most cases, a specific CPT code. The table below shows how they connect, followed by a detailed breakdown.

PhaseClinician ActionCPT Code2026 Reimbursement (National Avg.)
1. Enroll & EducatePatient selection, consent, device/app setup98975~$22
2. Remote MonitoringPatient transmits data at home; platform collects it98985 (2 to 15 days) or 98977 (16 to 30 days)~$51 for either code
3. Clinical Review & CommunicationReview data, make treatment decisions, communicate with patient98979 (first 10 min) or 98980 (first 20 min)~$26 / ~$54
4. DocumentRecord what was reviewed, interpreted, decided, and communicated(No separate code; supports billing above)N/A
5. BillConfirm thresholds, select codes, submit claims(All codes above)N/A

Phase 1: Enroll and Educate (CPT 98975)

Patient selection is where the RTM workflow starts. Not every patient is a good fit. The best RTM candidates are patients who have a meaningful home program, need accountability between visits, and benefit from active follow up. Think post surgical rehab patients, chronic low back pain patients with extensive HEPs, or anyone whose progress depends on what they do outside the clinic.

During enrollment, clinicians:

  • Verify the patient has an active plan of care and a qualifying MSK or respiratory diagnosis
  • Obtain informed consent for RTM monitoring
  • Educate the patient on the app or device, walking them through how to log exercises and pain scores
  • Set up the monitoring parameters in the platform
  • Document the enrollment, consent, diagnosis, and education provided

This initial setup typically takes 20 to 30 minutes per patient, combining education, a technology walkthrough, and a baseline assessment. For a step by step look at the enrollment process, see this guide on enrolling patients in remote monitoring. CPT 98975 reimburses approximately $22 at 2026 national average rates.

Phase 2: Remote Monitoring and Data Collection (CPT 98985 or 98977)

Once enrolled, the patient uses the RTM app at home. They follow their personalized home exercise program, log pain levels, and record adherence data. The platform transmits this information back to the clinician’s dashboard automatically.

This phase is where the patient does most of the work. The clinician’s role is passive here: the system collects the data. But the data collection period determines which device supply code you can bill.

The device supply codes are mutually exclusive. You bill either 98985 (2 to 15 days of data transmission) or 98977 (16 to 30 days) for the same patient in the same 30 day period. Never both.

This matters because patient adherence to home exercise programs is notoriously poor. Research consistently shows adherence rates between 35% and 50%, with non adherence as high as 70% in some studies. According to one pilot study, 81% of therapists reported that patients simply forget to do their exercises, and 64% said patients forget how to perform them correctly.

This is precisely why the 2026 addition of CPT 98985 was so important. Before 2026, if a patient only transmitted data for 12 days, you couldn’t bill anything. Now you can. More on that below.

For practical strategies to keep patients engaged with their programs, see these tips to increase patient engagement.

Phase 3: Clinical Review and Communication (CPT 98979 or 98980)

This is the clinical heart of the RTM workflow. The therapist reviews the incoming data, gains insights into exercise adherence, pain trends, and recovery progress, and uses that information to make treatment decisions.

Based on real time data, therapists adjust treatment plans when they see problems. If a patient reports worsening pain despite completing prescribed exercises, that triggers a program modification. If adherence is strong and pain is declining, the clinician might progress the HEP.

At least one real time interactive communication with the patient is required per month. This can be a phone call, a secure message exchange, or a video check in.

The treatment management time should reflect medically necessary management of the patient’s therapy plan. That includes reviewing adherence and response data, deciding whether care needs to change, updating the home program, communicating with the patient or caregiver, and documenting the clinical decisions that follow. For more on tracking what patients actually do between visits, see this guide on tracking patient activity between visits.

Like the device supply codes, the management codes are mutually exclusive. Bill either 98979 (first 10 minutes) or 98980 (first 20 minutes) for the same patient in the same calendar month. Never both. If your management time exceeds 20 minutes, you can add 98981 (each additional 20 minutes, ~$42 each).

Early data on RTM’s clinical impact is encouraging. Athletico Physical Therapy reported that RTM helped improve pain and function outcomes by more than 30% compared to patients not using RTM.

Phase 4: Document

Documentation is where most RTM programs fail. As one healthcare compliance firm put it: RTM reimbursement in 2026 is not primarily a coding challenge, it is a documentation and workflow challenge.

A compliant RTM interaction note should include:

  • The date and duration of the interaction
  • A reference to what monitoring data was reviewed
  • A clinical interpretation of what the data shows
  • The action taken or decision made based on that interpretation

Here is what a compliant note looks like compared to a non compliant one:

Compliant: “Reviewed 18 days of RTM data (exercise adherence 72%, avg. pain 4/10, down from 6/10 at enrollment). Patient reports improved function with stair climbing. Discussed via phone 3/12/2026. Progressed HEP to Phase 2 with added resistance. Will continue monitoring.”

Non compliant: “Reviewed RTM data. Patient doing well. Continue current plan.”

The second example will get denied. It shows no evidence that anyone reviewed the data meaningfully, no clinical interpretation, and no specific action.

RTM denials cluster around four documentation gaps: missing or incomplete patient consent, insufficient evidence of data transmission days, missing treatment management documentation showing time spent, and inadequate clinical review notes. For more on building documentation that holds up under scrutiny, see this RTM compliance codes and billing guide.

Phase 5: Bill

At month’s end, confirm your day counts and time thresholds, then select the correct codes. Remember the mutual exclusivity rules: one device supply code per 30 day period, one base management code per calendar month.

Only one clinician can bill RTM codes for a given patient in a 30 day period. And therapists must append the correct modifier to their claims:

  • GP for physical therapists
  • GO for occupational therapists
  • GN for speech language pathologists

For clinics managing RTM across multiple locations, platform automation for day counting, time logging, and code selection becomes essential to avoid billing errors.

Telehealth Place of Service Coding and RTM

A common source of confusion is whether RTM uses the same place of service (POS) codes as telehealth. It does not.

Telehealth services rendered via real time audio/video typically use POS 02 (Telehealth Provided Other than in Patient’s Home) or POS 10 (Telehealth Provided in Patient’s Home). RTM is not a synchronous telehealth encounter. CMS treats RTM as a service furnished under general supervision, which means the patient does not need to be face to face with the clinician when data is being transmitted or even when the clinician reviews it.

For RTM billing, clinicians should use the POS that reflects where the billing provider is located at the time of the service, typically POS 11 (Office) for clinic based therapists. The patient’s location during data transmission is irrelevant because RTM data flows asynchronously. According to the CMS Medicare Telehealth FAQ, telehealth POS codes apply specifically to synchronous encounters, not to remote monitoring programs.

Where this gets tricky is the required monthly interactive communication. If that communication happens over a quick phone call or secure message, it is part of the RTM management time and billed under 98979 or 98980 with the clinician’s office POS. It is not billed as a separate telehealth visit. Only if a clinician provides a full, distinct telehealth evaluation on the same day (with separate documentation and no time overlap) could a telehealth POS code come into play.

Practitioners on Reddit report that POS coding confusion is one of the top reasons RTM claims get kicked back during initial submissions. The fix is straightforward: bill RTM from your office POS and save the telehealth codes for actual synchronous visits.

EHR Integration and Workflow Templates

One of the biggest practical hurdles in the RTM clinician workflow is getting RTM data and documentation to play nicely with existing EHR systems. Most EHRs were not designed with RTM in mind, so clinics end up with a gap between the monitoring platform and the medical record.

The ideal setup is a two way integration where RTM data (adherence logs, pain scores, day counts) flows into the EHR automatically, and the clinician documents their review and decisions in the same place they chart everything else. In reality, few RTM platforms offer deep, native EHR integrations. Most rely on exportable reports that clinicians attach to the patient chart manually.

That manual step is where things fall apart. Practitioners on physical therapy forums describe a common scenario: they review data in the RTM platform, make clinical decisions, communicate with the patient, and then forget to document it in the EHR because the systems are separate. The result is compliant care with non compliant documentation.

A practical workaround is building an RTM workflow template directly inside your EHR. The template should include fields for:

  • Date and duration of review
  • Number of data transmission days this period
  • Summary of data reviewed (adherence %, pain trend, functional status)
  • Clinical interpretation
  • Action taken (HEP modified, patient contacted, no change with rationale)
  • Communication method and date

Some clinics create a dedicated RTM encounter type in their EHR so these notes are easy to find during audits. Others use a standardized smart phrase or macro that auto populates the required fields, reducing documentation time to under two minutes per patient. Clinicians who struggle with toggling between systems may find value in strategies to keep from switching between apps during clinical work.

The key principle: wherever the clinical thinking happens, the documentation must live in a place that auditors can find.

General Supervision and Clinical Staff Involvement

CMS classifies RTM services under “general supervision,” which is a significantly lower bar than the direct supervision required for many in clinic therapy services. Under general supervision, the supervising therapist does not need to be physically present when ancillary tasks are performed. They simply need to have provided the overall direction and be available if questions arise.

This opens the door for clinical support staff to handle portions of the RTM workflow, specifically the administrative and technical components. Front desk staff or therapy technicians can assist with:

  • Patient enrollment logistics (collecting consent forms, setting up app accounts)
  • Monitoring dashboard alerts and flagging patients who haven’t transmitted data
  • Sending reminder messages to patients who are falling behind on adherence
  • Compiling day count summaries for the billing team

What support staff cannot do is the clinical piece. The data review, clinical interpretation, treatment decisions, and patient communication about care plan changes must be performed by the qualified therapist (PT, OT, or SLP). PTAs and OTAs cannot independently furnish or bill RTM codes under the current CMS “sometimes therapy” classification, though they may assist under the supervising therapist’s direction.

This distinction matters for workflow design. The most efficient RTM programs separate the administrative pipeline from the clinical decision making. A therapy tech confirms that Patient A has 14 days of data transmitted and flags a pain spike on day 9. The therapist then reviews the data, interprets the trend, calls the patient, adjusts the HEP, and documents the encounter. The tech handles logistics; the therapist handles judgment.

For multi location clinics, this delegation model is what makes RTM scalable beyond a handful of patients per therapist. A well trained support person can manage the administrative side for 50 or more patients, freeing therapists to focus their blocked RTM time on the 10 to 15 patients who need clinical attention that week. More on how to standardize care plans across clinic locations in a related guide.

Monthly Review Scheduling and Reminder Workflow

The RTM clinician workflow is a monthly cycle, and cycles only work if they are built into the schedule with the same discipline as patient appointments. The clinics that struggle most with RTM are the ones that treat review time as something to squeeze in “when there’s a gap.”

There isn’t a gap. There is never a gap.

Building the Monthly Cadence

A practical monthly RTM schedule looks something like this:

Week 1 (days 1 to 7): Monitor new enrollments and early data transmission. Send a check in message to patients who haven’t logged any data by day 3. This early nudge is critical because practitioners consistently report that patients who don’t engage in the first week rarely catch up later.

Week 2 (days 8 to 14): First clinical review block. Review all active RTM patients. Identify anyone trending toward low adherence or concerning symptom patterns. Reach out to patients who need course corrections. Document these interactions.

Week 3 (days 15 to 21): This is the threshold window. Patients who have hit 16 days of data transmission qualify for 98977 instead of 98985. For patients hovering near the line, a targeted reminder message can make the difference between a $51 code and nothing at all.

Week 4 (days 22 to 30): Final review and billing preparation. Confirm all required interactive communications have occurred. Ensure documentation is complete. Run day count and time threshold reports. Submit claims.

Automating Reminders

Manual reminder systems do not scale. A therapist managing 25 RTM patients cannot realistically track who needs a nudge on which day using sticky notes or memory.

Effective reminder workflows operate on two tracks: patient facing and clinician facing.

Patient facing reminders go out automatically when the system detects inactivity. The best ones are brief, specific, and encouraging. “Hi Sarah, we noticed you haven’t logged your exercises since Tuesday. Your PT is reviewing your progress this week. Log today’s session so they can see how you’re doing.” That kind of message drives action without feeling like a nag.

Clinician facing reminders alert the therapist when a patient is approaching a billing threshold or when a required communication hasn’t happened yet. A dashboard that shows “Patient has 9 days of data, no interactive communication this month” at a glance saves the therapist from manually auditing each case.

One physical therapist shared in a YouTube walkthrough of their RTM process that they set calendar reminders for three fixed review blocks per week (Monday, Wednesday, Friday mornings for 30 minutes each) and found that this structure cut their monthly RTM admin time nearly in half compared to the ad hoc approach they used initially.

Explore how AC Health automates RTM reporting

2026 Updates That Changed the RTM Clinician Workflow

The 2026 Medicare Physician Fee Schedule Final Rule made the RTM clinician workflow substantially more practical. Before 2026, clinicians faced an all or nothing revenue cliff: if a patient transmitted data on only 15 days instead of 16, or if the clinician spent 18 minutes on management instead of 20, the entire month was unbillable.

CMS fixed this by adding two new codes:

  • CPT 98985 covers device supply for 2 to 15 days of data transmission (~$51). This is the lower threshold companion to 98977 (16 to 30 days).
  • CPT 98979 covers the first 10 minutes of treatment management time (~$26). This is the lower threshold companion to 98980 (first 20 minutes, ~$54).

According to analysis from Limber Health, this expanded billing flexibility could increase the number of billable RTM patients by 20 to 40%. That is a significant change for practices that were losing revenue every time a patient had a less engaged month.

The revenue math is compelling. A practice managing 100 MSK patients on full engagement RTM (98977 + 98980) generates approximately $10,500 per month, or $126,000 per year. Since RTM codes became billable in January 2022, claim volume has grown 412%.

RTM platform automation helps clinics track day counts and time thresholds automatically, so the correct code is selected without manual counting.

Why the RTM Clinician Workflow Breaks

Understanding the workflow on paper is one thing. Making it work in a packed clinical day is another. Here are the most common failure points.

Staff Buy In and Time Management

Practitioners on industry forums consistently report that RTM feels like “just another box to check.” One RTM consultant noted that if therapists don’t see the value in RTM for their patients, adoption will be half hearted at best. A PT writing for Medbridge shared a practical fix: “I changed this by modifying my schedule to block off dedicated time during the week to manage patient messages, follow ups, and focus on RTM.

The admin burden is real. Therapists already waste significant time on administrative tasks. Adding RTM without streamlining the process just compounds the problem.

Documentation Gaps Leading to Denials

As covered in Phase 4, incomplete documentation is the primary reason RTM claims get denied. The four gaps (consent, data evidence, time documentation, and clinical review quality) are all preventable with the right workflow and templates.

Patient Engagement Failures

If patients don’t use the app, there’s no data. If there’s no data, there’s nothing to review, document, or bill. The RTM clinician workflow depends entirely on patient participation. Practices that invest in patient compliance strategies and personalized content see dramatically better engagement than those using generic exercise libraries.

Treating RTM as Passive Revenue

Paul Singh of StrataPT raised an important concern on LinkedIn: too many clinics treat RTM as a passive revenue tool instead of a purposeful extension of care. Enrolling patients, ignoring the data, and billing the codes is not just ethically questionable, it is a compliance risk. The workflow exists because the clinical review and communication are supposed to improve outcomes. If they don’t, the program is hollow.

How to Make the RTM Clinician Workflow Sustainable

Start With a Pilot Group

Don’t enroll your entire caseload on day one. Pick 5 to 10 patients who are good candidates (active HEPs, motivated, tech comfortable) and run the full RTM workflow for two months. Learn where the bottlenecks are before scaling.

Block Dedicated RTM Time

Treat RTM review like any other clinical obligation. Block 30 to 60 minutes two to three times per week specifically for reviewing data, communicating with patients, and documenting. Trying to squeeze RTM into the gaps between treatments is how it falls apart.

Use Platform Automation

Manual day counting and time tracking across dozens of patients is unsustainable. The right RTM platform handles data aggregation, day count tracking, code state visual cues, and report generation so clinicians can focus on clinical decisions instead of spreadsheets. See how clinics have implemented these workflows in practice.

Invest in Personalized Content

Generic exercise libraries produce generic engagement. Patients are far more likely to use an app when they see their own clinician demonstrating their specific exercises. Custom, personalized video content drives the adherence that makes the entire RTM clinician workflow viable.

Ready to streamline your RTM workflow? Get a free walkthrough.

Frequently Asked Questions

What counts toward RTM treatment management time?

Time spent reviewing adherence and response data, deciding whether the care plan needs to change, updating the home exercise program, communicating with the patient or caregiver (phone, secure message, or video), and documenting clinical decisions. Administrative tasks like scheduling or billing do not count.

Can a PTA or OTA perform RTM tasks?

Under the current CMS “sometimes therapy” classification, RTM services must be furnished by qualified therapists (PTs, OTs, SLPs) or physicians. PTAs and OTAs cannot independently furnish or bill RTM codes, though they may assist under the supervising therapist’s direction. Under general supervision rules, the therapist does not need to be physically present for the ancillary work but must provide overall direction. Always check your state practice act and the latest CMS guidance.

What is the difference between device supply codes and management codes?

Device supply codes (98985 and 98977) reimburse for the technology and data collection infrastructure, based on how many days the patient transmitted data. Management codes (98979, 98980, 98981) reimburse for the clinician’s time spent reviewing data, communicating with the patient, and making clinical decisions. You need both categories to fully bill RTM each month.

Can I bill RTM and CCM for the same patient?

Yes, RTM and Chronic Care Management (CCM) can be billed for the same patient in the same month, as long as the services are distinct and the time counted toward each code does not overlap. The RTM time must reflect therapy specific management, while CCM time covers general chronic condition coordination.

How many patients can one therapist realistically manage on RTM?

This depends on workflow efficiency and platform automation. Most practitioners report that 20 to 30 active RTM patients per therapist is manageable with dedicated weekly review blocks. With support staff handling administrative tasks under general supervision, some therapists push closer to 40. Without automation, even 10 patients can feel overwhelming because of manual tracking requirements.

Does RTM require a separate patient visit?

No. RTM is explicitly designed for between visit monitoring. You do not need to see the patient face to face to bill RTM management codes. You do need at least one real time interactive communication per month, which can happen by phone or secure message.

What place of service code should I use for RTM?

Use the POS code that reflects where the billing clinician is located, typically POS 11 (Office). Do not use telehealth POS codes (02 or 10) for RTM claims. RTM is an asynchronous monitoring service, not a synchronous telehealth encounter.

What happens if a patient stops transmitting data mid month?

Under the 2026 codes, you can still bill 98985 if the patient transmitted data on at least 2 days during the 30 day period. If they transmitted zero days, there is no billable device supply event. You may still bill management time (98979 or 98980) if you spent at least 10 or 20 minutes on clinical review and patient communication during that month.

Do I need a separate EHR template for RTM documentation?

You don’t strictly need one, but clinics that build a dedicated RTM note template inside their EHR report significantly fewer documentation related denials. The template ensures no required field gets skipped and makes audits far less stressful.

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