Over the past year, I've had the same conversation dozens of times with mental health practitioners who ask me some variation of: "I've heard of remote monitoring, but isn't that just for blood pressure and diabetes?"
The answer is a resounding “no,” and the confusion between Remote Patient Monitoring (RPM) and Remote Therapeutic Monitoring (RTM) might be costing your practice, both clinically and financially.
Let me break it down.
RPM has been around since 2019 under Medicare. It uses connected medical devices (think blood pressure cuffs, pulse oximeters, or glucose monitors) to automatically transmit physiological data from a patient's home to their provider. It's been transformative for chronic disease management, but it tracks physiological metrics. This presents the key limitation for our field: mental health conditions don't produce blood pressure readings or blood oxygen levels. Conditions like depression, anxiety, PTSD, or eating disorders manifest through thoughts, behaviors, mood patterns, and functional impairment. Physiological monitoring alone doesn't capture the therapeutic picture.
That's exactly why CMS created RTM as a separate category.
RTM was introduced to capture non-physiological data related to therapeutic treatment. This includes therapy adherence, treatment response, medication compliance, and perhaps most critically, cognitive behavioral therapy (CBT) monitoring. Unlike RPM, RTM allows for patient self-reported data through digital tools. The patient doesn't need to be hooked up to a Bluetooth device transmitting numbers. They can use an app to complete structured assessments, log their mood, track their sleep habits, and record CBT homework completion.
This is a fundamental shift in what CMS considers "monitoring."
THE 5 PRACTICAL DIFFERENCES THAT MATTER MOST
First - data type. RPM captures physiological metrics (heart rate, weight, and blood pressure), while RTM captures therapeutic and behavioral data (mood, adherence, symptom patterns, and CBT engagement). If you're a therapist, psychologist, or psychiatrist, RTM is your lane.
Second - data sources. RPM data must be automatically transmitted by the device. RTM data can be self-reported by the patient, a critical distinction for mental health, where validated self-report measures like the PHQ-9, GAD-7, and functional assessments are the clinical standard.
Third - staffing and supervision. Both RPM and RTM treatment management services (codes 98980/98981) now operate under general supervision of the billing practitioner, as clarified in the CY 2023 Physician Fee Schedule final rule. However, the billing practitioner must be directly involved in the treatment management components.
Fourth - who can bill. Both RPM and RTM can be billed by physicians and non-physician practitioners. However, commercial payers may allow licensed mental health counselors, psychologists, and clinical social workers to bill RTM codes, even in cases where Medicare does not. For example, Anthem's coverage policy explicitly lists CPT 98975-98981 as RTM services, including 98978 for cognitive behavioral therapy. Check each payer's individual policy to see exactly what is covered.
Fifth - and this is crucial, you cannot bill both RPM and RTM for the same patient in the same month. It's one or the other.
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Now, here's why this distinction really matters for your practice: if you've been sitting on the sidelines because you assumed remote monitoring was "not for mental health," you've been operating under a misconception. RTM was designed with therapeutic monitoring in mind. CPT code 98978 was created specifically for cognitive behavioral therapy device supply. CMS is signaling, clearly, that between-session monitoring in behavioral health deserves reimbursement.
And yet, adoption in mental health remains surprisingly low. A significant number of behavioral health practices are leaving revenue on the table, not because they lack the clinical expertise, but because they don't realize the infrastructure now exists to get paid for work they're often already doing informally.
Think about it: How many of you already review patient journals, check in between sessions via a portal message, or ask patients to track their mood?
You're doing therapeutic monitoring. You're just not getting reimbursed for it.
RTM creates the billing framework to formalize and fund that work.
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In the next post, I'll dig into one of the most persistent challenges in behavioral health, premature therapy dropout, and explore how RTM offers a clinically grounded strategy to address it.
Until then, take five minutes to audit your current practice. How much between-session patient data are you already collecting, reviewing, or acting on? And are you capturing any of that value?
Let me know in the comments. 👇
REFERENCES & SOURCES
• CMS. CY 2023 Physician Fee Schedule Final Rule — RTM Supervision and Billing Clarifications. https://www.mwe.com/insights/cms-clarifies-coverage-and-payment-for-remote-therapeutic-monitoring-services/
• HHS Telehealth.gov. Billing for Remote Patient Monitoring. https://telehealth.hhs.gov/providers/best-practice-guides/telehealth-and-remote-patient-monitoring/billing-remote-patient