CPT 98981
Description, Billing Rules, and Use Cases

CPT 98981 Billing Requirements and Eligibility

CPT 98981 is used to report an additional 20 minutes of provider-performed treatment management under a Remote Therapeutic Monitoring (RTM) program. It is a time-based add-on code that must be used together with CPT 98980, and it only applies once the initial 20-minute threshold has been exceeded in a single calendar month.

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This code reflects extended clinical involvement in managing a patient's RTM plan, such as monitoring adherence, reviewing therapeutic response, and communicating with the patient to guide care.

Patient Eligibility Criteria

To be eligible for services billed under CPT 98981, the patient must:

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• Be actively enrolled in a Remote Therapeutic Monitoring (RTM) program

• Have a qualifying condition that requires continued oversight through RTM

• Use a device that meets the FDA definition of a medical device for therapeutic monitoring

• Receive ongoing treatment management services from a physician or qualified healthcare professional (QHP)

Device and Setup Requirements

While CPT 98981 does not cover device setup or supply, it requires that:

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• An RTM device is already in place and generating data during the billing month

• The device is assigned specifically to the patient and used to monitor:

  • Musculoskeletal function

  • Respiratory status

  • Therapy adherence

• The provider has access to the transmitted data and is actively using it to make care decisions

Billing Frequency and Time Requirements

CPT 98981:

• Can only be billed after CPT 98980 has been reported for the same calendar month

• Represents each additional 20-minute block of treatment management time

• Requires that total provider time during the month exceeds 20 minutes in 20-minute increments

• Must include at least one interactive communication with the patient or caregiver (live phone, video, or secure platform)

If total time spent is only between 1–20 minutes, only CPT 98980 may be reported. Time beyond the first 20 minutes must be documented clearly to support CPT 98981.

Who Can Bill CPT 98981

CPT 98981 may be billed by:

• Physicians

• Nurse Practitioners (NPs)

• Physician Assistants (PAs)

• Other Qualified Healthcare Professionals (QHPs)

It cannot be billed by clinical staff under general supervision. Time must reflect direct provider effort in delivering RTM treatment management services.

CPT 98981 Billing Documentation Checklist

To support compliant billing of CPT 98981, the following must be documented in the patient’s chart:

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• A valid RTM order from a physician or QHP

• Confirmation that CPT 98980 has already been reported for the same calendar month

• Description of the RTM device(s) in use:

  • FDA-defined as a medical device

  • Assigned specifically to the patient

  • Used for monitoring musculoskeletal, respiratory, or therapy adherence data

• Evidence that the provider completed an additional 20 minutes of treatment management time:

  • Reviewing and interpreting patient-generated data

  • Making or documenting changes to the treatment plan

  • Coordinating care with other clinicians

• A log of cumulative time tracked for RTM management:

  • Start/stop times or itemized time blocks

  • Time must clearly exceed the first 20-minute threshold reported under CPT 98980

• Documentation of at least one interactive communication with the patient or caregiver:

  • Date and method of communication (e.g., phone call, video visit)

  • Summary of the discussion or patient coaching

• Provider credentials and signature:

  • Must be a physician or QHP

  • Clinical staff activity may not be counted toward this time

• Confirmation that no conflicting time-based management codes were billed in the same calendar month:

  • Excludes 99091, 99457, 99458, 99473, 99474, and 93264

• Clinical justification for continued treatment management:

  • Ongoing RTM data review and therapeutic oversight

  • Response to symptom changes, adherence concerns, or device data trends