Best Practices for Billing Departments and Compliance Teams on Remote Therapeutic Monitoring (RTM)

Remote therapeutic monitoring (RTM) offers healthcare organizations a way to enhance patient care while receiving reimbursement for remote management services. However, some clinicians may hesitate to bill for RTM due to concerns about coverage variability, potential patient costs, and compliance risks.

Billing and compliance teams play a key role in developing structured processes that help clinicians navigate RTM billing while ensuring compliance with payer policies. This guide outlines widely used best practices for establishing RTM billing protocols that emphasize transparency, accuracy, and regulatory adherence.

1. Developing Internal RTM Billing Guidelines

Establishing RTM Billing Policies
Many organizations create standardized policies that define

• The CPT codes frequently used for RTM (e.g., 98975, 98977, 98980, 98981)
• The necessary documentation for each code
• Workflows for tracking patient interactions and clinical engagement

To make sure RTM codes are accurately understood during this process, it is beneficial to refer to official resources such as the American Physical Therapy Association (APTA) practice advisory resource: https://www.apta.org/your-practice/payment/medicare-payment/rtm-codes-practice-advisory

Standardizing Determining Patient Eligibility
It can be helpful to develop standardized policies that establish when RTM services can be billed. This often includes

• Outlining necessary documentation
• Defining patient engagement requirements
• Stating payer-specific billing guidelines

You may also find it useful to maintain reference guides summarizing payer coverage for RTM and their specific billing requirements. 

Some organizations create internal checklists or reference materials to ensure billing teams and clinicians understand when RTM codes apply and what documentation is needed to support reimbursement.

For further guidance on coding and compliance, organizations frequently reference resources from the Centers for Medicare & Medicaid Services (CMS) (www.cms.gov) and the American Medical Association (AMA) (www.ama-assn.org).

2. Addressing Clinician Concerns About RTM Billing

Some clinicians may be cautious about billing for RTM due to uncertainties around coverage and patient responsibility. To alleviate these concerns, organizations frequently implement different approaches.

Maintaining Updated Payer Coverage Information
It’s not uncommon for organizations to track which payers reimburse for RTM and outline any preauthorization or policy limitations, making sure this information is in the earlier internal policies and documentation.

• Set a cadence for updating policies and documentation.
• Ensure coverage reference information is easy for clinicians to reference when determining patient eligibility.

Clarifying Potential Patient Costs
To help clinicians feel more comfortable utilizing RTM, it’s helpful to ensure they understand when RTM services may be subject to copays, deductibles, or other out-of-pocket expenses.

Some organizations provide clinicians with scripting or educational materials to help communicate potential costs to patients.

Incorporating Insurance Verification and RTM Eligibility Checks into Workflows
Many administrative teams proactively check RTM coverage before enrolling a patient. Preauthorization steps may be built into the workflow if required by a specific payer.

Some organizations also build logic into their tools, such as their electronic health record systems, to flag RTM eligibility according to their internal policy. This can help inform clinicians when determining the appropriate care plan. Alternatively, an internal RTM resource may be used as a procedural document to be referenced at time of care.

3. Standardizing Documentation and Compliance Practices

Accurate documentation is essential for supporting RTM claims and maintaining compliance. There are a few common best practices when establishing documentation and compliance practices.

Establishing Clear Documentation Requirements
Many organizations require structured records of patient engagement, data collection, and provider interactions. Setting minimum documentation thresholds (e.g., ensuring an interactive communication for 98980) can help maintain compliance.

Implementing Standardized Clinical Note Templates
Some organizations develop documentation templates that capture key RTM-related activities, such as

• Patient-reported data and adherence trends
• Clinical assessments and treatment modifications
• Provider–patient interactions related to remote monitoring

Conducting Internal Reviews Before Claim Submission
It is common practice to review RTM claims for completeness and accuracy prior to submission. Periodic internal audits help ensure adherence to payer documentation standards.

4. Training Clinicians and Staff on RTM Billing Workflows

Providing training and ongoing education supports the effective integration of RTM billing into clinical practice. It can help to utilize some widely used strategies.

Offering Routine Training Sessions
Many organizations conduct educational programs covering

• When and how to initiate RTM services
• Proper documentation of RTM interactions
• Identifying patients who meet RTM billing criteria

Developing Quick-Reference Materials

Some organizations create checklists or decision trees to guide clinicians on when RTM billing is appropriate. It can also be helpful to provide examples of well-documented RTM encounters, which can improve adherence to documentation requirements.

Encouraging Open Communication

Organizations may hold Q&A sessions where clinicians can discuss concerns related to RTM billing. They may also address common misunderstandings about reimbursement proactively to help clinicians feel more confident incorporating RTM into their workflows.

5. Monitoring and Adjusting Processes

Payer policies for RTM may evolve over time, requiring ongoing monitoring and process adjustments. There are some key best practices to consider.

Assigning a Compliance Liaison for RTM
Some organizations designate a staff member to stay informed on payer policy changes and communicate updates to clinicians.

Tracking Claim Denials and Adjusting Workflows Accordingly
Reviewing RTM claim denials can help identify documentation gaps and refine billing workflows.

Engaging Directly With Payers
Many organizations communicate with payer representatives to clarify coverage policies and resolve any uncertainties regarding billing requirements.

Monitoring Provider Usage and Compliance
It can also be beneficial to monitor internally to see if clinicians are utilizing RTM with patients when the organization expects them to, based on internal policies. This can include setting up processes for monitoring and following up on certain behaviors, such as

• Are clinicians utilizing RTM when expected? Why or why not?
• Are clinicians reaching out to patients when there is low engagement, and if not, why not?
• Are clinicians following expected documentation practices? If not, why not?

By monitoring and adjusting expectations or workflows appropriately, organizations can help ensure clinician adherence to policies and, in turn, improve usage and billing rates.