Remote Therapeutic Monitoring Billing for Wound Care 2026

Most wound care practices bill for what happens at the bedside and stop there. Remote Therapeutic Monitoring (RTM) codes let you bill for the clinical work that happens between visits — reviewing patient-submitted wound photos, responding to symptom questionnaires, and making real-time care adjustments — without the physiologic device requirements that come with Remote Patient Monitoring (RPM). If remote therapeutic monitoring isn't in your billing stack yet, you're leaving recoverable revenue on the table on every non-healing wound you're actively managing.

What Remote Therapeutic Monitoring Is (and Isn't)

RTM was introduced by CMS in 2022 to fill a gap left by traditional RPM codes. RPM (99453–99458) requires monitoring of physiologic data — think blood pressure cuffs, glucometers, weight scales, pulse oximeters. RTM expands the definition to cover therapeutic response data: information about whether a treatment plan is working, collected through digital means. Wound condition updates — drainage changes, periwound appearance, pain scores, odor, patient adherence to offloading — are precisely the kind of therapeutic response data RTM was built for.

This distinction matters. A mobile wound care practice following a patient with a venous leg ulcer between weekly visits doesn't need a Bluetooth-connected scale to bill for remote monitoring. It needs a documented, structured way to collect wound status data and a clinician who reviews and acts on it.

RTM CPT Codes That Apply to Wound Care

Three codes form the RTM billing framework for wound care:

CPT 98975 — Remote Therapeutic Monitoring Setup (first month only) Covers initial device supply and patient education for therapeutic monitoring in the first calendar month. Requires a minimum of 20 minutes of clinical staff time during the setup period. Bill this once when you onboard a patient into an RTM program.

CPT 98980 — RTM Treatment Management, First 20 Minutes This is the primary monthly billing code. It covers a minimum of 20 minutes of clinical staff or physician time in a calendar month, plus at least one interactive real-time communication with the patient (phone, video, or secure messaging). This code is billed once per month per patient.

CPT 98981 — RTM Treatment Management, Each Additional 20 Minutes Add this for each additional 20-minute increment beyond the initial 20 minutes in the same month. Complex non-healing wounds with frequent check-ins can generate multiple 98981 units in a single billing period.

Both 98980 and 98981 can be billed by the ordering clinician or under general supervision by qualified clinical staff — a significant advantage for NP-led wound care practices.

What Does Not Qualify

CPT 98976 and 98977 are device supply codes tied to musculoskeletal and respiratory monitoring respectively. They do not apply to wound care monitoring and should not be billed for this service line. Wound care RTM is billed through 98975 for setup and 98980/98981 for treatment management.

What Counts as RTM Data in Wound Care

The data collected must be objective and documented within the clinical record. In a wound care context, qualifying data types include:

• Patient-submitted wound photographs with structured annotations (size, drainage, periwound changes)
• Validated symptom questionnaires (pain scale, odor severity, adherence to dressing change schedules)
• Patient-reported offloading compliance logs
• Wound measurement self-reports using calibrated measurement tools
• Alerts triggered by deterioration thresholds (e.g., drainage volume increase, temperature change)

The key requirement is that data is collected digitally and transmitted to the clinical team for review. Manual phone calls without a structured data collection mechanism do not qualify as RTM.

Documentation Requirements for RTM in Wound Care

Documentation is where RTM claims get denied. Your record must capture:

Time tracking: The clinical record must log the cumulative time spent reviewing RTM data, communicating with the patient, and adjusting the care plan during the calendar month. Time spent by clinical staff under supervision counts toward the threshold.

Interactive communication: At least one real-time, two-way communication with the patient per month is required to bill 98980. This can be a phone call, video visit, or secure message with synchronous exchange — document the date, time, and nature of the interaction.

Clinical decision-making: The note must reflect that the clinician reviewed the data and made (or deliberately did not change) a clinical decision. Documenting "wound photos reviewed, no change in care plan indicated at this time" satisfies this requirement. Silence does not.

Patient consent: RTM requires informed consent for remote monitoring. The consent should reference the type of monitoring, data collected, and how it will be used. Store this in the patient record.

For practices that rely on structured documentation, pairing RTM with a wound care documentation checklist designed to capture between-visit activity can reduce audit exposure significantly.

How RTM Fits Into a Mobile Wound Care Practice

RTM is particularly well-suited to mobile and home-based wound care models. In a traditional clinic, patients walk in for follow-up and the clinician sees the wound directly. In a mobile practice managing patients across SNFs, ALFs, and homes, the time between visits is long and wound deterioration can go undetected.

With RTM, your clinical workflow can expand to include:

1. Onboarding at the first visit: Set up the patient's RTM program, document informed consent, and bill 98975 in the first month.
2. Weekly photo submissions: Coach the patient or their caregiver to submit wound photos through a HIPAA-compliant portal or app.
3. Asynchronous review: A clinical staff member reviews submissions, logs review time, and flags any deterioration for same-day clinician review.
4. Monthly attestation: At month-end, verify that at least one interactive communication occurred, cumulative time meets the 20-minute threshold, and that clinical decision-making is documented. Bill 98980 (and 98981 if applicable).

If you're building or scaling a mobile practice, the mobile wound care business guide covers the infrastructure decisions — including technology selection — that determine whether RTM is operationally feasible from day one.

RTM vs. RPM: Choosing the Right Code Set

For patients with comorbidities driving wound complexity — diabetic patients with poorly controlled glucose, patients with hypertension affecting perfusion — you may have a case for billing both RPM and RTM concurrently. CMS has not issued a blanket exclusion on concurrent billing, but you must document that:

• The conditions monitored are distinct (physiologic data for RPM, wound therapeutic response for RTM)
• The monitoring programs are separately consented and documented
• Clinical staff time is tracked separately and not double-counted across codes

When in doubt, prioritize RTM for the wound-specific monitoring and consult your MAC's local coverage determinations before stacking both programs. See the remote patient monitoring guide for a detailed look at the RPM code set and its requirements.

Medicare Advantage and Commercial Payer Coverage

Medicare Part B covers RTM codes under the Physician Fee Schedule. Coverage by Medicare Advantage plans varies. Before onboarding a Medicare Advantage patient into an RTM program, verify:

• Whether the plan covers CPT 98975, 98980, and 98981
• Whether prior authorization is required (some MA plans require PA for remote monitoring programs)
• The plan's definition of qualifying monitoring technology

Document your pre-authorization steps. If an MA plan denies RTM claims retroactively claiming the technology didn't qualify, a contemporaneous record of the pre-authorization inquiry strengthens your appeal.

Commercial payer coverage is inconsistent. Medicaid coverage varies by state. Build a payer-specific RTM coverage grid and update it quarterly — this is not a set-it-and-forget-it reimbursement line.

Key Takeaways

• RTM codes 98975, 98980, and 98981 enable wound care practices to bill for between-visit monitoring of wound therapeutic response — no physiologic device required.
• The primary monthly billing code (98980) requires a minimum of 20 minutes of clinical staff or physician time AND at least one interactive communication with the patient per calendar month.
• Qualifying data includes patient-submitted wound photos, symptom questionnaires, and adherence logs collected through a HIPAA-compliant digital channel.
• Documentation must capture cumulative time, clinical decision-making, and patient consent — missing any element can trigger denial.
• Medicare Advantage plans vary in coverage; verify and document pre-authorization before starting RTM programs for MA beneficiaries.

Adding RTM to your billing model is a systems decision, not just a coding decision. The practices that capture it consistently are the ones that build the workflow — consent, data collection, time tracking, and monthly attestation — before billing the first claim. Get the infrastructure right and this revenue line compounds over your entire chronic wound population.