CPT 98975
Description, Billing Rules, and Use Cases
CPT 98975 is used for the initial setup and patient education related to Remote Therapeutic Monitoring (RTM). This code captures the time spent by a provider setting up RTM equipment and instructing the patient on its use, prior to ongoing monitoring and data analysis.
CPT 98975 is reported once per episode of care, defined as the period between the initiation of monitoring and the achievement of treatment goals.
What is CPT Code 98975?
CPT 98975 is a foundational code in the Remote Therapeutic Monitoring (RTM) family. It is billed when a provider performs the initial setup of the RTM device(s) and delivers education to the patient on how to use it.
This code typically applies when:
A medical device is supplied to monitor patient adherence or response to therapy
The provider offers hands-on instruction about using the equipment
The RTM episode begins (and is distinct from a prior episode)
The device is used to monitor functions such as:
Musculoskeletal or respiratory status
Cognitive behavioral therapy adherence
Medication response or symptom changes
CPT 98975 should only be reported:
Once per episode of care
If the monitoring period includes at least 16 days of data collection
With devices that meet FDA medical device criteria
In conjunction with a physician’s or qualified healthcare provider’s order
This code serves as the billing anchor for launching an RTM program. Subsequent services — such as data transmission (98976–98977) or treatment management (98980–98981) — must follow in a compliant care cycle.
CPT 98975 Billing Requirements and Eligibility
CPT 98975 is used to report the initial setup and patient education associated with launching an RTM (Remote Therapeutic Monitoring) episode of care. This includes the provision of a qualifying device, setup of monitoring logistics, and instruction delivered to the patient.
This code may only be billed once per episode of care, and must meet the following requirements:
Patient Eligibility Criteria
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The patient is being actively managed for a condition requiring remote therapeutic monitoring, such as:
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A musculoskeletal or respiratory condition
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A behavioral or neurological condition under digital therapy
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A treatment plan involving medication adherence, symptoms, or therapy response
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The patient must understand and consent to device use
Device and Setup Requirements
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The device used must:
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Qualify as a medical device under FDA guidelines
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Be capable of transmitting physiological or therapeutic adherence data
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Be assigned and set up for at-home use
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The provider (or trained staff under supervision) must:
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Provide and activate the device
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Instruct the patient or caregiver on how to use it
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Document all setup steps and educational instruction
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Timing and Episode Requirements
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CPT 98975 may only be reported:
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Once per episode of care
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When at least 16 days of data are collected within a 30-day monitoring window
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If there is no overlap with prior RTM services for the same episode
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A new episode must reflect:
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A new condition being monitored
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A restarted treatment plan or new therapeutic objective
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Provider Scope and Supervision
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The code may be billed by:
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Physicians
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Qualified healthcare professionals (NPs, PAs, etc.)
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Non-physician staff under general supervision if permitted by payer policy
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CPT 98975 Billing Documentation Checklist
CPT 98975 requires clear documentation that a qualifying device was provided and that patient education and setup occurred as part of a new RTM episode. To support compliant billing, include the following in the patient’s record:
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A documented order from a physician or qualified healthcare provider
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Must include the intent to begin RTM
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Should specify the condition being monitored and the device selected
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Description of the RTM device assigned
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Confirmed to meet the FDA definition of a medical device
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Able to capture and transmit therapeutic data
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Assigned uniquely to the patient
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A statement confirming initial setup and patient education were completed
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Who delivered the training (provider or supervised staff)
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When and how the training occurred (in-person, telehealth, etc.)
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What was covered (e.g., device activation, data capture instructions)
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Identification of the episode of care
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Clearly distinguish this from prior episodes (if applicable)
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Define goals, condition being monitored, and treatment plan parameters
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Confirmation that the patient:
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Was instructed on proper device use
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Understood the monitoring schedule
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Consented to participate in the RTM program
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A follow-up tracking plan:
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Expected timeline for monitoring period (≥16 days)
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Who will review the data (provider or care team)
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When and how clinical follow-up will occur
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CPT 98975 Time Thresholds and Code Combinations
CPT 98975 is used to report the initial setup and patient education for a Remote Therapeutic Monitoring (RTM) episode of care. This service is typically billed once per episode, provided certain conditions are met. These include use of a qualifying device, instruction provided by a physician or qualified healthcare provider (QHP), and a minimum data collection threshold during the monitoring period.
Use the chart below to determine whether 98975 can be reported based on your RTM activity:
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Important to Note:
CPT 98975 may be billed once per episode of care and must meet the following criteria:
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Device meets FDA medical device definition
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Service ordered by a physician or qualified healthcare provider
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Setup includes documentation of patient education
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At least 16 days of monitoring must occur within the 30-day period following setup
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A new episode of care must be clearly distinguishable (e.g., new condition or goal)
When to Use CPT 98975:
Common Scenarios and Use Cases
CPT 98975 should be used when a provider or supervised clinical staff initiates a new episode of Remote Therapeutic Monitoring (RTM) by supplying a qualifying medical device and delivering patient education on its use. The setup must be ordered by a physician or qualified healthcare provider and documented clearly, with at least 16 days of monitoring planned for the upcoming 30-day period.
Here are examples of how CPT 98975 is used in practice:
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Starting RTM for Post-Orthopedic Rehab
A physical therapist (under physician supervision):-
Provides a wearable RTM device to track range of motion
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Educates the patient on how to sync and log exercises
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Initiates an episode of care targeting recovery from a knee replacement
Billing: 98975 (once for initial setup and education)
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Launching RTM for COPD Monitoring
A respiratory provider:-
Orders an RTM spirometry device
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Demonstrates proper technique and data upload process to the patient
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Documents the device activation, care goals, and education provided
Billing: 98975 (once at episode start)
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Digital Therapy Program for Behavioral Health
A clinician:-
Enrolls the patient in a 12-week app-based CBT program
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Reviews the device login process, symptom tracking schedule, and privacy guidance
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Documents setup under general supervision and plans for data review
Billing: 98975 (at beginning of therapy episode)
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Common CPT 98975 Billing Mistakes
(and How to Avoid Them)
CPT 98975 is a one-time setup code for launching an RTM episode, but many providers overlook the strict criteria tied to device type, timing, and documentation. Avoid these common missteps:
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❌ Billing 98975 Without a Qualifying Device
The device used must meet the FDA definition of a medical device and be capable of transmitting data. Apps alone (e.g., journaling or symptom checklists) typically do not qualify unless paired with a compliant device. -
❌ No Patient Education or Setup Documentation
CPT 98975 requires that the provider (or supervised staff) deliver patient instruction on device use. If education is not documented, the code should not be billed. -
❌ Fewer Than 16 Days of Monitoring
You may only report 98975 if the patient completes at least 16 days of data capture in the 30-day monitoring period that follows. Shorter durations invalidate setup billing. -
❌ Billing Multiple Times in a Single Episode
CPT 98975 is limited to one use per episode of care. Billing more than once for the same episode — without a new condition, goal, or device — is not compliant. -
❌ No Distinction Between Episodes
If you’re restarting RTM for the same patient, you must clearly document:-
A new treatment plan or clinical goal
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A new monitoring condition
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Or a completely new care episode
Otherwise, it’s considered a continuation of the original episode and not separately billable.
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❌ Provider Oversight Not Documented
Even if setup and training are delivered by clinical staff, the service must be ordered and overseen by a physician or QHP. Failing to link the billing provider to the care episode is a frequent audit flag.