A Step-by-Step Playbook for Implementing RTM in Your Behavioral Health Practice

Understanding RTM is easy. Implementing it is where most practices quietly give up.

Now that you understand what RTM is, and see both the clinical value and the revenue opportunity, the real question is the hard one: how do you actually do it?

I’ve worked with enough practices to know that the gap between understanding an idea and implementing it is exactly where they lose steam. So let’s get practical. Here’s a step-by-step framework for launching RTM in a behavioral health practice.

Step 1: Choose Your Technology Platform

This is foundational. You need a digital tool that qualifies under CMS’s RTM framework, meaning it should function as or through an FDA-defined medical device (SaMD, Software as a Medical Device). At minimum, the platform should enable patient self-reporting of symptoms, mood, and therapy adherence; offer structured CBT exercises or psychoeducational content; automatically track and transmit data (or record patient-reported data) at least daily; generate clinician-facing reports and alerts; and support HIPAA-compliant data storage and transmission.

Evaluate platforms based on clinical validity, ease of use for both patients and clinicians, integration with your EHR or practice management system, and the vendor’s understanding of RTM billing requirements. If you’re unsure where to start, the APA’s App Evaluation Framework provides helpful criteria for evaluating digital mental health tools. Ultimately, the right platform should feel like a clinical tool, not a consumer wellness app.

Step 2: Identify Your Patient Population

RTM isn’t for every patient, and trying to enroll everyone from day one is overwhelming. Instead, start with a focused cohort. Good candidates include patients who are:

• Receiving CBT for depression, anxiety, or related conditions
• At elevated risk of dropout (early in treatment, inconsistent attendance, or low engagement)
• In the maintenance phase and benefit from continued monitoring without weekly sessions
• Comfortable with smartphone-based tools

Avoid starting with patients in acute crisis, those with significant digital literacy barriers (unless you have a support structure in place), or patients who are ambivalent about treatment. RTM works best when the patient is an active participant.

Step 3: Develop Your Onboarding Workflow

Patient onboarding maps directly to CPT code 98975. During an in-person visit (under Medicare, 98975 is not billable as a telehealth service), walk the patient through the digital tool. Explain what data will be collected, how often they should log in, what happens with their data, and how it enhances their treatment. Document the device or app used, the training provided, and confirmation that the patient activated the monitoring tool. Patient consent is required at the time RTM is furnished.

A few practical tips: create a standardized onboarding checklist so every patient gets the same orientation; set expectations clearly (this isn’t optional homework, it’s part of their treatment plan); and consider designating a team member (a care coordinator or digital navigator) to handle initial setup and troubleshooting, freeing clinicians to focus on clinical care.

Step 4: Establish Your Monitoring and Review Rhythm

Once patients are enrolled, someone on your team needs to monitor data compliance and clinical signals. This includes:

• Tracking which patients have met the 16-day data threshold for billing
• Reviewing incoming mood scores, assessment results, and engagement patterns
• Flagging patients whose data shows concerning trends
• Ensuring at least one interactive communication (phone or video) occurs with each enrolled patient per calendar month

Many practices designate a weekly or twice-weekly “RTM review block” where clinicians review their enrolled patients’ data. This concentrated approach is more efficient than ad hoc monitoring and makes time-tracking for 98980 and 98981 more straightforward.

Step 5: Integrate Data into Clinical Sessions

This is where RTM stops being administratively useful and becomes clinically powerful. Before each session, review the patient’s between-session data. Reference it directly in session. Use mood trends, assessment scores, and engagement patterns to guide your clinical focus. Beyond improving the quality of care, this strengthens the therapeutic alliance and gives patients tangible evidence that their between-session effort matters.

Step 6: Bill Correctly and Document Thoroughly

The RTM code set changed meaningfully on January 1, 2026, so if your billing logic is still built on the 2025 rules, you are likely leaving revenue on the table and exposing yourself to denials. Here are the reminders that matter, framed for a behavioral health program.

Setup:

• 98975 (setup and patient education) is billed once per episode of care. You need at least 2 days of monitoring data to bill it, not 16. The 16-day threshold applies to the device-supply codes, not to setup.

Device supply (the CBT-specific piece):

• 98978 is the cognitive behavioral therapy device-supply code, billed once per 30-day period when the patient transmits data on at least 16 days. One important caveat: unlike the respiratory and musculoskeletal supply codes, 98978 is contractor-priced. There is no national payment amount, so confirm your MAC’s rate before you build any revenue projection on it.
• 98986 is new for 2026. It lets you bill CBT device supply for just 2 to 15 days of data in a 30-day period, closing the old all-or-nothing gap at 16 days. You bill 98978 or 98986 in a given period, never both.

Treatment management (time-based, billed per calendar month):

• 98979 is also new for 2026: the first 10 to 19 minutes of treatment management. Months that fell short of 20 minutes used to be uncompensated.
• 98980 covers the first 20 minutes. 98979 and 98980 are mutually exclusive, so bill the single code that matches your actual cumulative time for the month.
• 98981 covers each additional 20-minute increment, and it adds onto 98980, not onto 98979.
• All three require at least one real-time interactive communication during the month. For 2026, CMS clarified this can be an audio-only phone call or an in-person conversation, not just video. Asynchronous contact (email, text, in-app messages) does not count.

Rules that trip practices up:

• Only one clinician can bill RTM for a given patient in a 30-day period. The first claim submitted wins.
• RTM and RPM cannot both be billed for the same patient in the same month.
• RTM can be billed concurrently with behavioral health integration (BHI) codes (99484, 99492-99494), but you cannot count the same time or effort toward two services.
• The device-supply codes run on a rolling 30-day period while the management codes bill per calendar month, so the two will not always land in the same statement. Plan for that mismatch.

To support billing, document everything: the device used and the patient’s data activity, the number of days of data transmitted, the time spent reviewing data and communicating with the patient, the clinical decisions the data informed, and each interactive communication (with date and modality).

Step 7: Monitor, Iterate, and Scale

Start small by enrolling your first 10 to 20 patients. From this group, learn what works and what doesn’t, using those observations to refine your onboarding script, data review workflow, and billing process. Solicit feedback from clinicians and patients, then expand.

The practices that succeed with RTM treat it as a clinical program, not a one-time project. They assign ownership, track metrics (enrollment rates, data compliance, billing capture, retention impact), and iterate continuously.

One final thought as you begin your implementation journey: it doesn’t have to be perfect from day one, but it does have to be intentional. The practices that wait for perfect conditions will wait forever. The practices that start, learn, and refine will be the ones that lead.

Next post: the emerging role of the digital navigator, a new team member who can make or break your RTM program.

What’s the first step you’re going to take? Drop it in the comments and let’s hold each other accountable.

#RTM #Implementation #BehavioralHealth #MentalHealth #PracticeManagement #HealthcareWorkflow #DigitalHealth #ClinicalExcellence

REFERENCES & SOURCES

CMS. Telehealth & Remote Monitoring (MLN901705, December 2025).]https://www.cms.gov/files/document/mln901705-telehealth-remote-monitoring.pdf

HHSTelehealth.gov. Billing for Remote Patient Monitoring (RTM concurrent billing rules).https://telehealth.hhs.gov/providers/best-practice-guides/telehealth-and-remote-patient-monitoring/billing-remote-patient

APA. App Evaluation Framework.https://www.psychiatry.org/psychiatrists/practice/mental-health-apps