TL;DR
An RTM report is the documentation artifact generated by a Remote Therapeutic Monitoring platform that summarizes patient data, provider actions, and time logs for a billing period. It supports CMS-1500 claim submissions for CPT codes 98975 through 98981 and serves as the compliance backbone of any RTM program. The 2026 CMS Final Rule significantly lowered billing thresholds, making RTM reports relevant to more patients than ever, but also raising the stakes for accurate documentation.
Every rehab clinic billing Remote Therapeutic Monitoring needs to produce one. Yet despite RTM generating growing attention (and growing audit scrutiny), no clear definition of “RTM report” exists anywhere online. Guides explain CPT codes. CMS transmittals outline policy. But the report itself, the actual document that holds your billing together, gets treated like an afterthought.
That’s a problem, because the RTM report is where clinical care, compliance, and revenue intersect. Get it wrong and you risk denied claims, clawbacks, or worse. Get it right and you unlock a revenue stream that one private PT practice credits with raising profit margins from 6% to 20%.
If you’re exploring how RTM fits into your practice, AC Health’s clinic solutions offer a good starting point for understanding the workflow.
What Is an RTM Report?
An RTM report is the documentation produced by a Remote Therapeutic Monitoring platform that captures everything needed to justify billing for RTM CPT codes. It consolidates patient monitoring data, provider treatment management activity, timestamps, interactive communication records, and code eligibility status into a single artifact that attaches to a CMS-1500 claim or uploads to an EMR.
Think of it as the receipt and the proof of work, combined. Without it, you have no auditable trail linking your RTM services to the codes you bill.
RTM itself is a set of CPT codes introduced in the 2022 CMS Physician Fee Schedule that allows healthcare providers to monitor patients remotely using FDA-qualifying devices or software. Unlike Remote Patient Monitoring (RPM), which tracks physiological data like blood pressure, RTM focuses on nonphysiological data: therapy adherence, pain levels, functional outcomes, and exercise completion. The RTM report is the documentation layer that makes this monitoring billable.
For physical therapists, occupational therapists, and speech-language pathologists, this distinction matters. RTM was built for rehab.
What Does an RTM Report Include?
Based on CMS requirements and APTA practice advisories, a compliant RTM report must contain these elements:
Platform and device identification. The name of the RTM platform, its description, and its FDA classification (typically Software as a Medical Device, or SaMD). This establishes that the monitoring tool meets CMS requirements.
Data transmission tracking. The exact number of days that patient data was transmitted within the 30-day billing period. This is critical because it determines which supply code applies: 98985 for 2 to 15 days, or 98977 for 16 to 30 days.
Patient-reported data summary. Aggregated information the patient submitted, such as pain scores, exercise adherence rates, and functional outcome measures. This is the clinical substance of the report.
Provider review and decision logs. Timestamped entries showing when a provider reviewed patient data, what actions they took, and how RTM insights influenced care decisions. CMS expects clinical reasoning here, not generic restatements of the data.
Interactive communication record. Documentation of at least one phone or video interaction with the patient during the billing month. Treatment management codes require this.
Cumulative treatment management minutes. The total time a provider or clinical staff spent on RTM activities during the calendar month, broken into the relevant threshold (10 to 19 minutes or 20+ minutes).
Code-state summary. A clear indicator showing which CPT codes are billable based on the data collected, including any new tiered codes.
Patient consent documentation. Evidence that the patient consented to RTM services, either in advance or at the time services were furnished.
Device setup and training records. For the initial billing period, documentation of the education provided to the patient or caregiver and any device configuration performed.
A well-built RTM report makes all of this exportable in a format ready for CMS-1500 attachment or EMR upload. Software that tracks these elements automatically eliminates the manual assembly that burns hours of staff time.
Which CPT Codes Does an RTM Report Support?
The RTM report exists to justify billing for specific CPT codes. The 2026 CMS Final Rule expanded this code family with two new additions, creating a tiered structure that did not exist before.
Device Setup
| Code | Description | Billing Frequency | Approx. Reimbursement |
|---|---|---|---|
| 98975 | Initial setup and patient education on RTM equipment | Once per episode of care | ~$22 |
An episode of care begins when RTM services start and ends when established treatment goals are met.
Device Supply (Musculoskeletal)
| Code | Description | Data Threshold | Approx. Reimbursement |
|---|---|---|---|
| 98985 (NEW 2026) | Device supply, 2 to 15 days of data transmission in 30 days | 2-15 days | ~$51 |
| 98977 | Device supply, 16 to 30 days of data transmission in 30 days | 16-30 days | ~$40 |
Treatment Management
| Code | Description | Time Threshold | Approx. Reimbursement |
|---|---|---|---|
| 98979 (NEW 2026) | Treatment management, 10 to 19 minutes per calendar month | 10-19 min | ~$26 |
| 98980 | Treatment management, initial 20 minutes per calendar month | 20+ min | ~$54 |
| 98981 | Each additional 20 minutes (add-on to 98980) | 20 min increments | ~$41 |
Revenue math. A fully qualifying RTM patient can generate approximately $135 per month in ongoing revenue (98977 + 98980 + 98981), or about $157 in the first month with setup code 98975 included. Reimbursement data sourced from 247 Medical Billing Services and Limber Health’s 2026 analysis.
When therapists furnish RTM services, the appropriate therapy modifier (GP for physical therapy, GO for occupational therapy, GN for speech-language pathology) must be appended to the claim. The RTM report should reflect which modifier applies. Only one provider can bill RTM codes for a given patient within a single 30-day period.
2026 CMS Rule Changes Affecting RTM Reports
The changes finalized for January 1, 2026 represent the most significant evolution of RTM since its introduction in 2022. They fundamentally change what an RTM report needs to track.
The old problem
Previously, RTM billing required at least 16 days of data collection within a 30-day period and a minimum of 20 minutes of provider management time. This was an all-or-nothing cliff. If a patient transmitted data for only 14 days, or a provider logged 18 minutes of review time, the entire month was unbillable. Practitioners frequently called this the “16-day trap.”
Patient compliance has been the number one complaint from clinic owners attempting RTM. When reimbursement depends on patients remembering to sync their devices for 16 out of 30 days, too many billing periods end with nothing to show for the effort.
What changed
The 2026 Final Rule introduced tiered billing that eliminates the cliff:
- Data threshold lowered. New code 98985 allows billing when data is transmitted for just 2 to 15 days in a 30-day period. You no longer need 16 days to bill a supply code.
- Time threshold lowered. New code 98979 allows billing for 10 to 19 minutes of treatment management per month. You no longer need a full 20 minutes.
- Tiered structure. Providers can bill at either the lower or higher threshold, depending on actual patient engagement that month.
- New Technology List. All RTM codes remain on the CMS New Technology List through April 2030, protecting them from budget neutrality adjustments.
What this means for RTM reports
RTM reports now need more granular logic. At the end of each billing period, the report must determine whether the patient falls into the 2-to-15-day or 16-to-30-day tier for device supply, and the 10-to-19-minute or 20-plus-minute tier for treatment management. Getting this classification wrong means billing the wrong code.
Understanding this RTM workflow for clinics is essential before setting up your reporting process.
RTM Report vs. RPM Report
This confusion comes up constantly, so it’s worth addressing directly.
RTM (Remote Therapeutic Monitoring) tracks nonphysiological data. Pain scores, exercise adherence, functional status, therapy homework completion. The data can be patient-reported through SaMD tools; it does not require automatic physiologic capture. RTM codes are primarily used by physical therapists, occupational therapists, and speech-language pathologists.
RPM (Remote Patient Monitoring) tracks physiological data. Blood pressure, heart rate, weight, blood glucose. RPM requires automatic data upload from a medical device. RPM codes are primarily used by physicians and nurses.
The critical billing rule: RTM and RPM cannot be billed together by the same practitioner for the same patient during the same period. An RTM report and an RPM report serve different clinical workflows, cover different data types, and fall under different code families.
For rehab providers, RTM is almost always the relevant path. RPM simply doesn’t capture what therapy practices need to monitor.
RTM Report Documentation Best Practices
Only about 1.6% of Medicare patients are currently receiving RTM, which suggests most clinics are either not implementing it or failing at it. Documentation quality is a big reason why. Here’s how to get it right.
Document clinical reasoning, not just data
CMS expects providers to show how RTM insights influence care decisions. A note that says “patient reported 4/10 pain” is not enough. The report needs to capture what you did with that information. Did you adjust the home program? Move up a follow-up appointment? Modify exercise intensity? The clinical reasoning is what separates a compliant RTM report from a liability.
Track cumulative minutes with built-in timers
Treatment management codes bill based on time, and that time must be documented. Manual tracking on spreadsheets is error-prone and hard to defend in an audit. The practical approach, as one PT practitioner shared, is to submit RTM codes as a group per patient after the month ends, using software that automatically tracks rules and produces the appropriate CPT codes when criteria are met.
Record patient consent before the first bill
Practitioners must obtain consent either in advance or at the time RTM services are furnished. This consent must be documented in the patient’s record. Missing consent documentation is an easy audit flag to avoid.
Maintain one-provider-per-patient discipline
Only one provider can bill RTM codes for a given patient in a 30-day period. If multiple therapists treat the same patient, the clinic needs a clear internal policy on who “owns” that patient’s RTM billing.
Prepare for OIG scrutiny now
The Office of Inspector General’s 2024 and 2025 reports have focused heavily on RPM, and similar scrutiny for RTM is widely expected. OIG found that 43% of Medicare enrollees receiving RPM did not receive at least one of the three required service components. The parallel for RTM is clear: your reports must cover setup, device supply, and treatment management to avoid triggering audit flags.
A September 2024 OIG report specifically urged additional oversight of remote monitoring services, leading to a significant increase in audits across RPM, CCM, and related virtual care programs. RTM clinics should treat this as a warning shot.
For practical strategies on keeping patients engaged with their monitoring, see these tips to increase patient engagement.
Why RTM Report Automation Matters
Manual RTM tracking is the single biggest barrier to adoption. One PT practice owner presenting at APTA put it bluntly: the biggest pitfall is dumping RTM on clinical staff, because your PTs do not have an extra 60 minutes per month to monitor dashboards.
Practitioners on forums and at conferences describe what some call the “toggle tax,” the friction of switching between an EMR and a standalone RTM dashboard to piece together documentation. Every toggle is a chance for missed data, incomplete records, or wasted time.
Effective RTM report automation should handle:
- Automatic day counting. The platform tracks how many days patient data was transmitted and flags when the 2-day, 15-day, or 16-day thresholds are crossed.
- Built-in time tracking. Provider review time is logged as it happens, not reconstructed from memory at month’s end.
- Code eligibility indicators. Visual cues showing which CPT codes are billable for each patient, updated in real time as thresholds are met.
- One-click report generation. The complete RTM report, ready to attach to a CMS-1500 or export to an EMR, without manual assembly.
- Interactive communication logging. Phone and video contacts recorded within the platform to satisfy treatment management requirements.
The financial case for automation is strong. One private PT practice documented a 277% increase in profit per case after implementing a structured RTM program, with per-case profit jumping from roughly $104 to $362-$393. That kind of return only works if the documentation process doesn’t eat into the margin.
To see how improving patient experience drives revenue beyond just RTM billing, the connection between engagement and financial outcomes runs deep.
Explore AC Health’s RTM-ready pricing plans to see how automated RTM reporting fits into your practice.
Putting It All Together
The RTM report is not a nice-to-have add-on. It is the document that determines whether your RTM program generates revenue or generates audit risk. With the 2026 CMS changes lowering barriers to entry and OIG enforcement ramping up across remote monitoring, the stakes for getting RTM documentation right have never been higher.
The clinics succeeding with RTM share a common pattern: they automate the report, integrate it into existing workflows, and treat documentation as a clinical activity rather than an administrative burden.
If you’re ready to see how automated RTM reporting works in practice, schedule a demo with AC Health and walk through the workflow with their team.
Frequently Asked Questions
What is the purpose of an RTM report?
An RTM report serves two purposes. First, it acts as a clinical record showing what patient data was monitored and how it informed care decisions. Second, it provides the billing justification needed to submit CMS-1500 claims for RTM CPT codes 98975 through 98981. Without a complete RTM report, claims lack the documentation backbone that CMS and auditors require.
How is an RTM report different from an RPM report?
RTM reports document nonphysiological data like pain scores, exercise adherence, and functional outcomes, typically collected through patient self-reporting in SaMD apps. RPM reports document physiological data like blood pressure and heart rate, captured automatically by medical devices. The two cannot be billed together for the same patient by the same provider in the same period.
What changed about RTM reporting requirements in 2026?
The 2026 CMS Final Rule introduced tiered billing with lower thresholds. New code 98985 covers data transmission for 2 to 15 days (previously, 16 days minimum was required). New code 98979 covers 10 to 19 minutes of treatment management (previously, 20 minutes minimum). RTM reports must now classify each patient into the correct tier at the end of every billing period.
How many days of patient data does an RTM report need to show?
As of 2026, a minimum of 2 days of data transmission within a 30-day period qualifies for billing under code 98985 (~$51 reimbursement). For the higher-tier code 98977 (~$40), 16 to 30 days of data transmission are required. The RTM report must clearly document the exact number of transmission days.
Can clinical staff generate RTM reports, or must the treating provider do it?
Clinical staff can perform data collection and monitoring activities under general supervision of the billing practitioner. However, treatment management codes (98979, 98980, 98981) require at least one interactive communication with the patient by the billing provider or qualified clinical staff. The RTM report should document who performed each activity and their credentials.
What are the biggest audit risks related to RTM reports?
The OIG found that 43% of Medicare RPM enrollees were missing at least one required service component, and similar enforcement patterns are expected for RTM. The main risks include incomplete consent documentation, missing interactive communication records, billing without meeting minimum day or time thresholds, and failing to document clinical reasoning for care decisions based on RTM data.
How much revenue can RTM generate per patient?
A fully qualifying patient generates approximately $135 per month in ongoing RTM revenue (combining device supply and treatment management codes), or about $157 in the first month with setup code 98975 included. One documented case study showed a private PT practice increasing profit per case from $104 to $362-$393 after implementing structured RTM, representing a 277% increase.
Do I need special software to create an RTM report?
You don’t technically need specialized software, but manual tracking is widely cited as the top barrier to successful RTM implementation. RTM platforms that auto-track transmission days, log provider time, flag code eligibility, and generate exportable reports dramatically reduce the documentation burden and lower audit risk compared to spreadsheet-based approaches.
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