RTM bridges the gap between therapy sessions, giving therapists real-time visibility into patient progress and a new reimbursable revenue stream for the clinical work they're already doing.
Mental health conditions cost the U.S. healthcare system over $280 billion annually. Research consistently shows that therapy outcomes improve when patients engage with structured exercises between sessions — completing CBT homework, tracking mood patterns, practicing skills.
Yet most therapists have zero visibility into what happens between Tuesday and the following Tuesday. Patients journal, have breakthroughs or breakdowns, skip their exercises, or disengage entirely — and the therapist doesn't know until the next session (or until the patient stops showing up).
Remote Therapeutic Monitoring (RTM) was created by CMS to address exactly this problem — giving clinicians the tools and reimbursement to monitor patients between visits using digital technology.
RTM enables therapists to monitor a patient's therapy adherence and treatment response between sessions using a qualifying digital device. Unlike Remote Patient Monitoring (RPM), which collects physiological data like blood pressure, RTM collects non-physiological data — mood scores, exercise completion, symptom tracking, and patient-reported outcomes.
With Extended Sessions AI, the workflow is simple:
1. Prescribe — You add a patient to Extended Sessions AI and configure the AI assistant to align with your therapeutic approach (CBT, DBT, ACT, etc.).
2. Patient Uses the App — Between sessions, your patient engages with structured CBT exercises, mood tracking, journaling, and guided reflection. The app collects and transmits data on therapy adherence and treatment response.
3. Review & Bill — You review patient data on your therapist dashboard, have at least one interactive communication (phone or video call) with the patient during the month, and bill RTM codes for your time.
RTM codes have evolved significantly since their introduction, with CMS steadily expanding flexibility and coverage — especially for behavioral health applications.
RTM codes launched. CMS created five new CPT codes (98975–98981) for remote therapeutic monitoring, covering musculoskeletal and respiratory conditions. PTs, OTs, and SLPs could bill for the first time.
CBT monitoring code added. CMS finalized CPT 98978, a new device supply code specifically for cognitive behavioral therapy monitoring — opening RTM to behavioral health professionals for the first time.
Coverage clarifications. CMS clarified that RTM does not require an established patient relationship, that the 16-day data requirement does not apply to treatment management codes, and that SaMD qualifies as a medical device for RTM purposes.
Major expansion. Three new codes (98979, 98984/98985, 98986) lower thresholds to 2–15 days of data and 10 minutes of clinician time. Behavioral health professionals now have more flexible, lower-risk entry points for RTM billing.
The following CPT codes are relevant to therapists using Extended Sessions AI. Codes are divided into two categories: device supply codes (for the app collecting data) and treatment management codes (for your time reviewing data and communicating with patients).
| CPT Code | Description | Frequency |
|---|---|---|
| 98975 | Initial setup and patient education on use of RTM equipment | Once per episode of care |
| 98978 | Device supply for CBT monitoring — 16–30 days of data in a 30-day period | Once per 30 days |
| 98986 | Device supply for CBT monitoring — 2–15 days of data in a 30-day period | Once per 30 days |
| 98979 | Treatment management — first 10–19 minutes per calendar month (requires one interactive communication) | Once per month |
| 98980 | Treatment management — first 20 minutes per calendar month (requires one interactive communication) | Once per month |
| 98981 | Treatment management — each additional 20 minutes per calendar month (add-on to 98980 only) | Per 20-min increment |
You cannot bill 98979 and 98980 in the same month — use one or the other based on total time. You cannot bill 98978 and 98986 in the same 30-day period for the same patient. RPM and RTM codes cannot be billed together for the same patient in the same month. Only one clinician can bill RTM for a given patient in a 30-day period.
One of the most common questions therapists ask about RTM is: "Don't I need some kind of physical device?" The short answer is no. CMS requires that RTM services use a medical device as defined by the FDA — but the FDA's definition is broader than most people realize, and it explicitly includes software.
Under Section 201(h)(1) of the Federal Food, Drug, and Cosmetic Act, a medical device is defined as:
"An instrument, apparatus, implement, machine, contrivance… or other similar or related article, including a component part, or accessory which is intended for use in the diagnosis of disease or other conditions, or in the cure, mitigation, treatment, or prevention of disease."
The FDA has confirmed that standalone software — including mobile applications and web-based platforms — qualifies under this definition when it is intended for a medical purpose. This category is known as Software as a Medical Device (SaMD).
Extended Sessions AI is SaMD: it is standalone software intended to support the treatment and mitigation of diagnosed mental health conditions by monitoring therapy adherence and treatment response. It is not a general wellness app — it is prescribed by a licensed therapist for patients with diagnosed conditions, as part of an active treatment plan.
Critically, meeting the FDA's device definition does not require FDA clearance or approval. Many SaMD products — including platforms already used for RTM billing across the country — operate under the FDA's enforcement discretion framework for lower-risk software. CMS has never required that an RTM device hold 510(k) clearance or PMA approval. The requirement is that the device meet the statutory definition — and software qualifies.
When CMS finalized the RTM code set, they made a deliberate choice: they refused to publish a list of approved devices. This wasn't an oversight — it was a policy decision to avoid stifling innovation and to trust clinicians to choose the right tools for their patients.
In the CY 2023 PFS Final Rule, CMS stated:
"We note that our proposals do not include a specific RTM device list, nor specific examples of RTM devices that would be appropriate for use when furnishing RTM services. We believe that a possible unintended consequence of express reference to a device, or list of devices, may include a preference or shift toward use of one device or class of device simply because of its inclusion on a list.
"We believe that the pace of innovation and evidence-based clinical decision-making inherent to use of the devices that support furnishing RTM services calls for medical and behavioral health professionals, groups of behavioral health and medical professionals, or professional societies, each to study carefully the needs of the populations under their care, and identify guidelines that shape selection and use of any specific device in clinical practice."
— 87 Fed. Reg. 69,404 (Nov. 18, 2022)
Two things stand out in this language. First, CMS explicitly names "behavioral health professionals" as intended RTM users — this isn't a physical therapy program being stretched to fit mental health. Behavioral health was written into the framework from the start, reinforced by CMS's concurrent creation of CPT 98978 for cognitive behavioral therapy monitoring in the same rulemaking.
Second, CMS directed clinicians to the FDA's SaMD guidance page in the same Final Rule, confirming that software platforms are recognized within the RTM device framework. The message is clear: CMS wants clinicians — including behavioral health professionals — to adopt the digital tools that best serve their patients, and to be reimbursed for doing so.
Remote Therapeutic Monitoring is intended to supplement your therapy sessions, not replace them. It gives you visibility into your patients' lives between visits — their mood patterns, exercise adherence, treatment response — so you can intervene sooner, adjust treatment plans with real data, and get reimbursed for the clinical work you're already doing. Extended Sessions AI makes this seamless.
Join the therapists who are closing the between-session blind spot and getting reimbursed for it.
Request a Demo