Operational Trends Shaping CPT Code 98981 Compliance in 2026
Remote care billing is, in fact, evolving faster than many practices anticipated. As such, CPT code 98981 has kind of emerged as a key tool for physicians managing therapeutic interventions outside traditional visits. With CMS shifting expectations around remote therapeutic monitoring (RTM) cpt codes, understanding 98981 is, well, not just helpful, it’s essential. This blog breaks down how physicians can actually use this code operationally in 2026, sort of navigate compliance updates, and avoid common billing pitfalls.
To be fair, CPT 98981 isn’t exactly new, but its importance in the Medical reimbursement landscape has definitely expanded. It’s specifically used for subsequent months of remote therapeutic monitoring, where the patient is already on an RTM plan. Typically, this applies to people dealing with, say, musculoskeletal pain, respiratory conditions, or behavioral symptoms that require continued follow-up.
In terms of usage, CPT 98981 applies after CPT 98980 (the first month) and reflects at least 20 minutes of time spent monitoring and interacting with the patient. And actually, unlike some RPM codes, this one requires interactive communication, not just device data.
CPT 98981 Billing Guidelines for Remote Therapeutic Monitoring
So, who can bill this? Well, only physicians and qualified healthcare professionals, not just any auxiliary staff, can report CPT 98981. The device or software must, kind of, capture relevant symptom data like medication response or pain progression. CMS is pretty specific here: it must be a therapeutic monitoring device, not just a general health tracker.
There’s also a bit of nuance to the documentation. For example, even though the communication can happen over phone or video, it has to be real-time, and yeah, that needs to be documented clearly.
Can You Bill CPT 98981?
✔ Patient Enrolled
They must be registered in a valid remote therapeutic monitoring program.
✔ 20+ Minutes of Reviewed Data
Review at least 20 minutes of recorded patient data during the month.
✔ Valid Therapeutic Tool
Use FDA-approved or clinically supported digital tools to collect data.
✔ Real-Time Interaction
Include live communication with the patient as part of the management.
CPT Code 98981 Time Requirements and Documentation Rules
Maybe the most common mistake practices make with 98981 is, oddly enough, under-documenting time. CMS requires:
- ≥20 minutes per calendar month of relevant activities
- At least one interactive communication session (not asynchronous)
- Documented use of therapeutic device data
In practice, that means tracking time spent on reviewing patient data, logging clinical decisions, and documenting that interactive communication, even if it felt routine or minor at the time.
CPT 98981 Time + Communication Requirements
| CCC | Minimum Standard | CMS Compliance Notes |
|---|---|---|
| Total Monitoring Time | ≥20 minutes/month | Must be clearly documented per individual patient |
| Interactive Communication | Required (1/month) | Real-time only, audio or video |
| Device/Data Capture | Therapeutic device needed | Not just general health trackers or apps |
CPT 98981 vs 98980: Key Differences for Clinical Billing
Actually, the difference between these two codes is more straightforward than most think, but still easy to get wrong
- 98980 is billed during the first month of remote therapeutic monitoring
- 98981 is billed for every month after that, assuming time and communication are still documented
Clinically, they’re used in similar contexts, but operationally, they mark different points in the billing cycle. Many denials happen when 98981 is accidentally billed too early, or documentation doesn’t meet the 20-minute threshold.
Comparison: CPT 98980 vs 98981
| Code | Description | Time Requirement | Use Case |
|---|---|---|---|
| 98980 | Initial RTM Setup + 20 mins | ≥20 mins | First month only |
| 98981 | Follow-up RTM | ≥20 mins | Subsequent months |
Emerging Operational Trends Impacting CPT 98981 Compliance
Looking ahead into 2026, several new trends are shaping how practices manage CPT 98981. Some are, to be honest, quite promising, while others introduce more layers of oversight.
- AI-assisted documentation:
This might sound futuristic, but it’s already here. AI tools now sort of auto-log session time and communication to reduce clinician effort. - VBC integration:
RTM codes are now being pulled into value-based care contracts,
especially for chronic and behavioral conditions. - Audit-ready workflows:
With increased scrutiny from CMS and the OIG, practices need airtight time tracking and communication logs. - Smarter EHR sync:
Platforms that auto-sync RTM data to the EHR, without manual work, are now more or less expected.
2026 Trends Shaping RTM Compliance
✔ AI-Powered Monitoring
Automated data analysis and alert triggers will drive real-time responses.
✔ Value-Based Care Models
RTM will increasingly tie into patient outcomes and risk-based contracts.
✔ OIG Compliance Scrutiny
Stricter oversight on time logs, consent, and documentation standards.
✔ Seamless EHR Integration
Improved syncing with health records will reduce billing errors and delays.
Avoiding CPT 98981 Denials: Operational Best Practices
Denials often come down to minor, but unfortunately common, missteps:
- Forgetting to log interactive communication
- Falling short of the 20-minute monthly threshold
- Using a platform that doesn’t log time properly
- Billing 98981 in the wrong month (before 98980)
To reduce risk, practices should kind of standardize their RTM process. That might mean using automated logging tools, assigning staff to double-check documentation, or just building in monthly internal checks.
Pro tip: Keep a shared checklist for 98981 eligibility that includes time log review, device compliance, and a note on the interaction type.
CPT 98981 Integration in Value-Based Care Models
This code isn’t just for billing, it actually fits really well into value-based care programs. CPT 98981 supports ongoing therapeutic monitoring for patients with chronic musculoskeletal, pulmonary, or behavioral conditions.
In the context of ACOs or advanced APMs, RTM data can help show:
- Symptom improvement
- Medication adherence
- Functional outcomes over time
This is where RTM adds actual clinical and operational value, especially when used with chronic care management or behavioral health integration strategies.
Choosing the Right RPM/RTM Platform for CPT 98981 Billing
Not every platform is built with CPT 98981 in mind. A lot of tools still prioritize RPM (like 99457), and sort of tack on RTM features later.
To be compliant and audit-ready, practices should ask:
- Does it track 20+ minutes/month, per patient, automatically?
- Are real-time interactions timestamped and logged properly?
- Is the platform designed for RTM, not just repurposed RPM?
You also want something that fits, more or less seamlessly, into your existing workflow. If staff have to bounce between systems or manually enter time, the risk of denials, and burnout, goes up fast.
FAQ's
What does CPT code 98981 cover under remote therapeutic monitoring?
CPT 98981 is used for subsequent months of remote therapeutic monitoring when clinical staff provide 20+ minutes of treatment management services. It applies after the initial month (billed under 98980), covering ongoing patient support, RTM data review, and communication required to manage musculoskeletal or respiratory conditions.
What are the Medicare reimbursement rules for CPT 98981 in 2026?
In 2026, Medicare reimburses CPT 98981 when providers meet CMS criteria: 20+ minutes of clinical time, valid RTM data (non-physiologic), and at least one synchronous interaction. Compliance with supervision, documentation, and use of approved monitoring devices is essential to secure reimbursement and avoid denials.
What is the minimum time and communication required to bill CPT 98981?
To bill CPT 98981, providers must document at least 20 minutes of RTM treatment management within a calendar month. There must also be at least one real-time (audio or video) interactive communication between the provider and patient, this proves clinical engagement and justifies the code under Medicare rules.
How does CPT 98981 differ from CPT 98980?
Well, CPT 98980 is used for the first month of RTM treatment management, while CPT 98981 applies to subsequent months. Both require 20+ minutes and a live communication, but 98980 typically includes the initial review of data and care plan creation, 98981 assumes those have already been done.
Can SmartCare360 streamline CPT 98981 compliance and billing?
Yes, SmartCare360 helps practices monitor RTM time logs, manage synchronous communication records, and ensure billing alignment for CPT 98981. While it doesn’t deliver clinical services, it supports provider teams with the backend operational tracking needed for CMS compliance, audit readiness, and revenue cycle consistency.
