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What is CPT code 98975? The one-time RTM setup and patient education code, with billing rules, the 2-day floor, and what documentation has to include.
Every Remote Therapeutic Monitoring program starts with one code: CPT code 98975. It covers the front-end work of an episode of care, though it isn’t billed at the moment of setup. At least 2 monitored days have to occur first, and only then can the code be submitted. After that, 98975 never appears again for the same patient unless a new episode of care begins.
On paper, 98975 looks simpler than the recurring codes. In practice it raises questions the others don’t: what counts as a new episode of care, when a returning patient can trigger a fresh 98975, and what “patient education” actually has to include to hold up under audit.
What follows covers how the code works, the 2-day floor that catches many clinics off-guard, the episode-of-care rule, how 98975 pairs with the rest of the RTM set, and the operational steps that make setup go cleanly.
CPT code 98975 compensates clinics for the work of getting a patient set up on RTM: introducing the program, capturing consent, providing access to the device or platform, and educating the patient on how to use it during their episode of care.
The code has a dual nature. It pays for both the setup mechanics, platform onboarding, account creation, device configuration, and the educational component, where the clinician explains how RTM fits into the patient’s care. Both pieces matter, and both need to be documented.
Worth being clear about one thing: 98975 isn’t billed for the time spent on setup. It’s a flat, one-time charge per episode of care that recognizes the front-end work as a distinct service, the same reimbursement whether the clinician spent 20 minutes or 8 minutes on the patient’s setup.
Here’s the requirement that catches many clinics off-guard: CPT code 98975 cannot be billed until at least 2 monitored days have been recorded. The patient has to actually start using the platform before the setup code can be submitted.
The rationale is straightforward. The floor exists to prevent billing for setup that didn’t lead to real patient engagement, protecting both the patient and the Medicare benefit from being charged for programs that never started. Operationally, that means 98975 sits in a queue after enrollment, not billed at the moment of setup, clinics need a workflow that holds the code until the floor is met and then submits it cleanly.
The foundational rule shaping CPT code 98975 is simple to state and surprisingly hard to apply: the code can only be billed one time per episode of care for the same patient.
Which raises the question of what an episode of care actually is. CMS guidance generally ties this to the plan of care, a single course of treatment for a treatable condition, with a defined start and end tied to clinical goals. When the plan of care closes, the episode closes with it. When a new plan of care is established for a new clinical issue, a new episode begins.
All RTM codes (98975 included) are anchored to the plan of care. The difference is that setup and patient education only happen once per episode, which is why 98975 is only billed once. The other codes capture recurring activities that bill according to their own windows: 98985 and 98977 every 30 days, and 98979, 98980, and 98981 every calendar month.
One of the most common questions about this code: a patient finishes their episode of care, discharges from RTM, and returns six months later for a different issue. Can the clinic bill 98975 again for the new program?
The general principle is yes, a genuinely new episode of care with a new plan of care can support a new 98975. The clinical situation is different, the treatment goals are different, and the program is being set up fresh. The caveat is that the documentation has to clearly support that this is a new episode, not a continuation of the prior one. Billing 98975 again for the same patient without a clearly documented new episode is a denial pattern that surfaces in payer reviews.
The “patient education” component of CPT code 98975 isn’t a checkbox. It needs to be substantive enough to support the patient actually using the platform throughout the episode of care, which means the education has to cover real, practical content, not just an acknowledgment that RTM was explained.
Reasonable patient education for 98975 typically covers how to access the platform, how to record data or complete activities, what the data is being used for, how the clinician will respond to it, and how to reach out with questions. The patient should leave the setup conversation able to use RTM on their own.
Documentation of the education matters as much as the education itself. A vague entry that reads “instructed patient on use of RTM platform” is weaker than a specific note describing what was taught, what was demonstrated, and what the patient confirmed they understood.
Documented patient consent has to be captured before CPT code 98975 can be billed. The consent needs to cover the patient’s understanding of the service, the associated cost-sharing, and the option to discontinue the program at any time.
The common failure pattern is consent that gets handled verbally during the setup conversation but never formally documented, the clinician explains, the patient agrees, the conversation moves on, with no signed form or electronic confirmation in the chart. That creates audit exposure that doesn’t surface until claims get reviewed months later. Consent belongs to the 98975 workflow itself, not as a separate process, capturing it at the front end is significantly easier than reconstructing it later.
CPT code 98975 sits at the front of the RTM code system. After 98975 comes 98985 or 98977 per 30-day device-supply period, followed by 98979, 98980, or 98981 per calendar month for management time. The setup happens once; everything else recurs. The 2026 RTM CPT code overview has a code-by-code walkthrough of how each one works.
A first-month scenario shows how the codes layer together. A patient enrolls on January 12, generates 10 monitored days by February 10, and receives 18 minutes of management time during January with one interactive communication. The billing: 98975 (Initial RTM setup, after the 2-day floor is met) + 98985 (RTM device capturing 2-15 days of MSK data in 30 days) + 98979 (10-19 minutes of RTM treatment-management time in January). From there, every subsequent month for the same episode runs without 98975. The code only fires once.
Several scenarios disqualify 98975 from being billed. The most common: the patient never reaches the 2-day floor, meaning they enrolled but never actually transmitted data through the platform. Without 2 monitored days on the record, there’s no claim to submit. Other disqualifying scenarios include setups that were administrative-only without genuine patient education, and cases where 98975 was already billed for the same episode of care.
It’s worth being honest about the design here: 98975 isn’t a make-the-program-pay code. If a patient enrolls and disengages immediately, the clinic doesn’t get to bill 98975 just to recover the setup time invested. The floor and once-per-episode rule together ensure the code reflects programs that actually started, not enrollments that didn’t.
Audit-ready 98975 documentation needs to capture: documented patient consent before the program began, evidence that patient education was substantive (what was taught and what the patient confirmed), proof of at least 2 monitored days before billing, identification of the device or platform used, and clear linkage to an active plan of care.
The documentation patterns that fail reviews are predictable: setup notes that don’t describe what was actually taught, missing or incomplete consent records, or 98975 billed before the 2-day floor was actually met. One useful reframe: setup documentation isn’t just for the 98975 claim. The patient education captured at setup becomes reusable evidence throughout the rest of the RTM episode.
Medicare recognizes CPT code 98975 for physicians, PTs, OTs, and SLPs, with the 2024 CMS Final Rule clarifying general supervision rules for PTAs and OTAs. Practically, this means the device supply and patient education portion can be delivered by a qualified assistant on a later date of service, as long as the inclusion and necessity of RTM are documented in the overseeing PT, OT, or SLP’s initial evaluation plan of care, and the assistant documents the work at the time of service. In that scenario, the claim is billed with the appropriate assistant modifier.
Coverage isn’t uniform across all payers. SLP-billed RTM has been inconsistent under Medicare in practice, chiropractors aren’t currently covered under Medicare for RTM, and commercial payers may have specific documentation requirements for the setup code that go beyond what Medicare requires. Verifying coverage per patient before enrollment is faster than chasing denials after submission.
Wibbi captures the setup workflow in one structured flow. Consent is documented at enrollment, patient education is delivered through the platform itself, monitored-day tracking automatically confirms when the 2-day floor is met, and 98975 documentation is prepared for submission at that point, not before.
Holding 98975 until the floor is verifiably met removes one of the most common billing mistakes: clinics submitting setup codes before the patient has actually engaged. The platform handles the setup workflow the same way across rehab disciplines, whether the clinic is running physical therapy programs for orthopedic recovery, occupational therapy for ADL training, speech therapy for communication rehab, pediatric cases with caregiver involvement, chiropractic programs, or pelvic health rehabilitation.
Bill CPT code 98975 once per episode of care, after at least 2 monitored days have been recorded, with documented patient consent and substantive patient education in place. The code never bills twice within the same episode of care.
Denial triggers to watch: billing before the 2-day floor is met, billing 98975 twice within the same episode of care, missing consent documentation, or vague education records that don’t describe what was actually taught.
National average reimbursement for 98975 in 2026 is $21.72, with actual payment shaped by Medicare locality.
This article is informational and isn’t intended as billing or legal advice, verify the latest CMS guidance and consult your billing team before submitting claims.
