RTM CPT Codes for Spine Practices: 98975, 98977, 98980, and 98981 Explained
Remote therapeutic monitoring (RTM) lets a spine practice bill for monitoring work it is often already doing — reviewing post-op pain trends, walking activity, and exercise adherence between visits. Four CPT codes do most of that work: 98975 (setup), 98977 (data supply, with the 16-of-30-day rule), and 98980/98981 (management time). This page explains each code's requirements, the 16-day rule, what documentation survives an audit, and the question surgical practices ask first: what happens during the 90-day global period.
RTM vs. RPM in one paragraph
RTM is remote monitoring of non-physiologic data: therapy adherence, therapy response, pain scores, and functional status — the things a recovering fusion patient reports or a monitoring platform records about how treatment is going. Remote physiologic monitoring (RPM) is the older sibling that covers physiologic data — blood pressure, glucose, weight, pulse oximetry. A spine practice tracking daily pain 0–10, walking minutes, exercise-program adherence, and patient-reported wound status after surgery is squarely in RTM territory, and 98977 is specifically defined for monitoring the musculoskeletal system. If you are capturing vital signs from a connected cuff or scale, that is RPM and a different code family entirely — the two are commonly confused, and billing the wrong family is an easy way to generate denials.
The four RTM codes spine practices use
| CPT code | What it covers | Key requirements | How often |
|---|---|---|---|
| 98975 | Initial setup and patient education on the RTM device or platform | Document that the patient was set up and taught to use the monitoring tool | Once per episode of care |
| 98977 | Device/data supply for musculoskeletal system monitoring | Data transmitted on at least 16 of 30 days in the period | Per 30-day period |
| 98980 | First 20 minutes of RTM treatment-management services | Full 20 minutes of documented time plus at least one interactive communication with the patient or caregiver during the month | Per calendar month |
| 98981 | Each additional 20 minutes of RTM treatment-management services | Each unit requires a full additional 20 documented minutes in the same month as a billed 98980 | Per calendar month, as earned |
The documentation that survives an audit
Across all four codes, auditors look for the same four things. If your program can produce these on demand, you are in good shape:
- The platform or device used — what the patient was set up on, and when (this is also your 98975 documentation).
- Transmission-day counts — which calendar days had data, so the 16-of-30 threshold for 98977 is provable rather than asserted.
- Time logs for 98980/98981 — dates, minutes, who did the work, and the interactive communication for the month.
- The care actions taken — what the data changed: a medication adjustment, a program modification, reassurance after a review, an escalation. Time with no recorded action is the classic audit failure.
The 16-day rule
98977 requires data transmission on at least 16 distinct days out of the 30-day period. Distinct calendar days are what count, not data points: a patient who submits a morning pain score, an afternoon walking entry, and an evening note has logged one day, not three. A patient who checks in 15 days out of 30 does not meet the threshold, and the code should not be billed for that period.
Two practical consequences follow. First, the 16-day rule makes patient adherence a billing input — a program patients find tedious quietly falls below threshold. The easier the daily check-in, the more months clear 16 days. Second, you need the day-count before billing, per patient, per period — bookkeeping that goes wrong fast in a spreadsheet. Your platform should show distinct transmission days against the threshold, not just a pile of data.
The 90-day global period question
This is the spine-specific issue that generic RTM articles skip, and it matters because most fusions carry a 90-day global period — precisely the window when monitoring is most valuable.
The general rule: the practitioner who received the global surgical payment typically cannot separately bill RTM treatment-management time (98980/98981) during the 90-day global period, because routine post-operative management is already included in the global payment. Billing management time for reviewing your own post-op patient's data inside the global window is double-billing the same work.
But the rule is about who holds the global payment, not about RTM itself:
- A different practitioner can bill. If a physical therapist (or another practitioner who did not receive the global payment) runs the monitoring program, their RTM management time is generally separately billable even during the surgeon's global period.
- Monitoring beyond the global period is billable. Once the 90 days end, the surgeon's own RTM management time is no longer bundled — and many spine patients benefit from monitoring well past day 90.
- Commercial payers vary. Some follow Medicare's global-period logic, some do not, and some have their own RTM policies entirely. Verify with each payer before assuming either answer.
How the setup and supply codes (98975/98977) interact with the global period is payer-specific as well — confirm the treatment of every code in the family with your MAC rather than extrapolating from the management-time rule.
Know whether the month actually hit 16 days — before you bill it
SpineOS generates a per-patient RTM documentation report: distinct data-days counted against the 16-day threshold and a met/not-met status for each code, built from the patient's real check-in stream. Documentation support for your billing team — your practice makes the billing decisions.
Browser-based · No PACS required · Decision support, not autonomous diagnosis.
What a post-op spine RTM program looks like in practice
The mechanics are simpler than the code descriptions suggest. A workable program has three parts:
1. A data source patients actually use. In a SpineOS-based program, the patient side is EasySpine — a free iPhone app (currently in early-access beta via TestFlight) plus a web portal. The daily check-in asks one question at a time: pain 0–10, walking (auto-filled from Apple Health, so the patient doesn't count anything), and wound status. Each completed check-in is a transmission day; because the check-in takes under a minute, the 16-day threshold becomes a byproduct of normal recovery tracking rather than a nagging project. Validated outcome surveys like the Oswestry Disability Index run through the same stream, adding functional-status data alongside the daily entries.
2. Someone reviewing the data and acting on it. This is where 98980/98981 time comes from — a clinician or staff member reviewing trends, contacting patients (there's your interactive communication), and adjusting the plan. Given the global-period rule above, many spine practices structure this so a PT or other non-global practitioner runs the management side during the first 90 days.
3. A monthly documentation report. At the end of the period, SpineOS assembles the month's RTM documentation: the distinct data-day count versus the 16-day threshold and a per-code met/not-met status. It's the audit-facing paper trail — transmission days, thresholds, and status — generated from the data rather than reconstructed from memory. The same patient-generated data stream also feeds the conservative-care documentation that prior-authorization packets depend on, so one program serves two documentation problems.
To be precise about the boundary: SpineOS produces documentation support. It does not submit claims, assign codes to encounters, or tell you what is billable for a given payer — those are decisions for your practice and its billing team.
Frequently asked questions
What data counts for CPT 98977?
98977 covers device or data supply for monitoring the musculoskeletal system, and RTM is defined around non-physiologic data: therapy and exercise adherence, therapy response, pain scores, and functional status that a patient reports or a platform transmits. Physiologic data like blood pressure or glucose belongs to RPM, not RTM. To bill 98977, the data must be transmitted on at least 16 distinct days of the 30-day period. Confirm current definitions and device requirements with your MAC and each payer.
Can a surgeon bill RTM during the global period?
Generally, no for the management time. The practitioner who received the 90-day global surgical payment typically cannot separately bill RTM treatment-management time (98980 and 98981) during the global period, because routine post-operative management is already included in the global payment. A different practitioner, such as a physical therapist running the monitoring program, generally can bill their own RTM management time, and monitoring that continues beyond the global period is billable. Commercial payer policies vary, so verify with each payer and your MAC.
How many days of data does RTM require?
The 16-day rule applies to 98977: data must be transmitted on at least 16 of 30 days in the monitoring period. Distinct calendar days are what count — three check-ins submitted on the same day still count as one day. The management codes 98980 and 98981 are time-based per calendar month (20-minute increments) rather than day-count based, and 98980 also requires at least one interactive communication with the patient or caregiver during the month.
What documentation does an RTM audit look for?
Four things, consistently: the platform or device used for monitoring; transmission-day counts showing whether the 16-of-30-day threshold was met for 98977; time logs for 98980 and 98981 with dates, minutes, and what was done, including the required interactive communication; and the care actions taken in response to the data, such as a medication adjustment, a program change, or an escalation. Time claimed with no recorded action or communication is the pattern that fails audits.
Do commercial payers cover RTM the same way Medicare does?
Not reliably. Commercial policies vary on which RTM codes they recognize, how they treat the 90-day global period, and which practitioner types may bill. Before building a program around RTM revenue, verify coverage and billing rules with each of your major payers and confirm Medicare specifics with your MAC. This page is general education, not billing advice.
See the RTM report your billing team wishes it had
Patients check in through EasySpine — pain, walking from Apple Health, wound status — and SpineOS turns the month into an RTM documentation report with data-day counts and per-code status. Bring a real patient month to the demo and we'll walk through it.
Browser-based · No PACS required · Decision support, not autonomous diagnosis.