For decades, mental health clinicians have known what the reimbursement system has been slow to acknowledge: that what happens between therapy sessions matters just as much as what happens during them.
Consider CBT homework, mood tracking, behavioral experiments, thought records, or exposure hierarchies practiced in real-world settings. All of these are core therapeutic activities that unfold outside the office and, until recently, none of them generated a single billable event.
That changed with CPT code 98978.
Introduced by the American Medical Association and refined through CMS policy, 98978 is the device supply code specifically designated for cognitive behavioral therapy monitoring. It covers the monthly cost of a digital therapeutic or FDA-defined device used to monitor CBT-related data (like mood tracking, symptom assessments, therapy exercise completion, and anxiety patterns) for at least 16 days within a 30-day period.
Let me translate that into clinical terms: if your patient uses a qualifying digital tool to track their CBT-related progress for at least 16 days in a month, you can bill for the device supply under 98978. That's in addition to the treatment management codes (98980 and 98981) that reimburse the clinical time you spend reviewing that data and communicating with the patient about it.
Here's the full RTM code family and how they work together for behavioral health:
98975 covers the initial setup and patient education, such as onboarding the patient to the monitoring platform, explaining how to use it, and activating their account. This is billed once per episode of care, after at least 16 days of data collection. The national average reimbursement is approximately $19-22 (varies by year and locality).
98978 covers the monthly device supply for CBT monitoring, including the digital tool itself, data transmission, scheduled recordings, and programmed alerts, and is billable once every 30 days when the 16-day data threshold is met. The reimbursement rate for 98978 is currently contractor-priced by CMS, meaning your Medicare Administrative Contractor (MAC) sets the rate based on the device costs you document. Commercial payers like Anthem have already listed 98978 in their coverage policies.
98980 covers RTM treatment management and reimburses providers for the first 20 minutes per calendar month of provider time spent reviewing patient data, analyzing trends, and communicating with the patient. This requires at least one interactive communication (a real-time, synchronous, two-way audio interaction: i.e., phone or video call) during the month. The national average reimbursement is approximately $50.
98981 is the add-on code for each additional 20-minute increment of treatment management in the same month. There is no limit on how many times 98981 can be billed per month, which is significant for complex cases requiring more clinical engagement. The national average reimbursement is approximately $39 per increment.
Let's do some rough math. For a single patient enrolled in RTM with a qualifying CBT monitoring tool:
Initial month: 98975 (~$20) + 98978 (contractor-priced) + 98980 (~$50) = approximately $70-120 in the first month, depending on the device pricing and your MAC.
Subsequent months: 98978 + 98980 = approximately $50-100 per month per patient, with additional 98981 increments if more than 20 minutes of treatment management is performed.
For a practice with 50 patients enrolled in RTM, that's potentially $2,500 to $5,000 in additional monthly revenue for clinical work that directly improves patient outcomes.
Now, here are a few important compliance considerations to keep in mind:
You can only bill one device supply code (98976, 98977, or 98978) within a 30-day period per patient. For behavioral health, 98978 is your code. Thus, RTM and RPM cannot be billed simultaneously for the same patient in the same month. Choose one pathway.
The 16-day data collection threshold is a minimum. The patient must have at least 16 days of recorded data (scheduled recordings or programmed alerts) within the 30-day billing period to qualify for reimbursement.
Treatment management codes (98980 and 98981) require at least one real-time, two-way audio communication with the patient or caregiver during the calendar month. A portal message alone does not satisfy this requirement.
98975 is not a telehealth service under Medicare; it must be provided in person (POS 11 or 12). Only one provider may bill these RTM codes per patient per month.
To support reimbursement, documentation is critical. Record the device or software used, the patient's data transmission activity, the clinical review performed, and the interactive communication that occurred.
One area that's still evolving is CMS's definition of qualifying devices and software for 98978. CMS has acknowledged that the technologies for cognitive behavioral therapy monitoring are still developing, with claims data and device costs under examination to establish clearer pricing guidelines. The JAMA Health Forum viewpoint by Ekekezie, Hartstein, and Torous (2023) proposed minimum standards for CBT-based RTM software: it should enable patient symptom reporting, integrate with wearables or smartphone sensors for objective data, offer psychoeducation on CBT principles, and protect patient privacy.
The bottom line is that 98978 is not a peripheral billing code. It's a deliberate policy signal from CMS that between-session mental health monitoring deserves its own reimbursement pathway. And, for practices that build the right workflows, it represents a meaningful, sustainable revenue stream tied directly to better patient care.
In the next post, I'll lay out the full business case for RTM in a behavioral health practice, including the revenue projections, the cost considerations, and the operational changes required to make it work.
Have you started billing 98978 yet? What's been your experience with payer acceptance? Share your story below.
#CPTCodes #RTM #98978 #MentalHealthBilling #CBT #BehavioralHealth #PracticeRevenue #DigitalTherapeutics#RemoteTherapeuticMonitoring
REFERENCES & SOURCES
• Ekekezie, O. Obi E. , Hartstein, G.L., & Torous, J. G. Luke Hartstein MD, MBA (2023). Expanding Mental Health Care Access — Remote Therapeutic Monitoring for Cognitive Behavioral Therapy. JAMA Health Forum, 4(9), e232954. https://jamanetwork.com/journals/jama-health-forum/fullarticle/2809663
• CMS CY 2023 Physician Fee Schedule Final Rule — RTM Clarifications (McDermott Will & Emery analysis). https://www.mwe.com/insights/cms-clarifies-coverage-and-payment-for-remote-therapeutic-monitoring-services/
• ThoroughCare. 2025 Remote Therapeutic Monitoring CPT Codes. https://www.thoroughcare.net/blog/2025-remote-therapeutic-monitoring-cpt-codes
• PYA. Providing and Billing Medicare for Remote Patient Monitoring (2024). https://www.pyapc.com/wp-content/uploads/2024/01/Providing-and-Billing-Medicare-for-RPM-PYA-010924.pdf
• CarePaths. CPT Code 98975 — RTM Setup and Behavioral Health Context. https://carepaths.com/reference/cpt-codes/98975/