Remote Therapeutic Monitoring Versus Remote Patient Monitoring

RPM tracks physiologic data that a device uploads automatically. RTM tracks how a patient is responding to or following a therapy, can use data the patient reports, and can be billed by clinicians who cannot bill evaluation and management services, such as physical therapists. How the two differ, why you can't bill both for one patient at once, and what the 2027 proposals would change for RTM.

Remote patient monitoring (RPM) collects physiologic data, such as blood pressure, weight or oxygen saturation, from a device that uploads it digitally. Remote therapeutic monitoring (RTM) tracks therapy adherence and response, such as musculoskeletal, respiratory or cognitive behavioral therapy status, and can use data the patient reports through a device. RTM also exists so that clinicians who cannot bill evaluation and management services, including physical and occupational therapists, can bill for monitoring. For any one patient, Medicare pays for RPM or RTM alongside other care management, not both.

How are they different?

Type of data. In the CY2022 fee schedule final rule, CMS described the difference: RTM codes "allow non-physiologic data to be collected," and RTM data "can be patient reported, as well as digitally uploaded while RPM requires that data be physiologic and be digitally uploaded."
Device. For both, the device must meet the definition of a device in section 201(h) of the Federal Food, Drug, and Cosmetic Act. A plain spreadsheet or a general wellness app does not qualify.
Who can bill. RPM treatment management codes are evaluation and management services. CMS noted in the CY2022 rule that physical therapists, for example, are not permitted to furnish E/M services, and that RTM was created in part so practitioners who cannot bill RPM can furnish similar services. CMS designates some RTM codes as "sometimes therapy."
Condition-specific device codes. RTM device supply codes are specific to respiratory system status, musculoskeletal system status, and cognitive behavioral therapy. RPM device codes are not condition-specific.

Where do the two overlap?

Both have three components: setup and education, device supply with data, and treatment management.
Both gained short-period device codes (2 to 15 days) and 10-minute management codes on January 1, 2026, in the CY2026 final rule. See what the 2-to-15-day codes change.
Both management code sets require a live, interactive communication with the patient or caregiver, under the CPT language CMS adopted for 2026.
Only one practitioner may bill the device supply codes for a patient in a 30-day period.

Can a patient get both RPM and RTM?

Not billed together. In the CY2024 fee schedule final rule, CMS stated that practitioners "may bill RPM or RTM, but not both RPM and RTM," concurrently with chronic care management, transitional care management, behavioral health integration, principal care management or chronic pain management, and noted that the CPT codebook bars reporting RTM treatment management with RPM treatment management. Pick the program that fits the patient's main clinical need.

Which fits which service line?

Hypertension, heart failure, diabetes with connected glucose or weight data: RPM.
Post-surgical rehabilitation, chronic musculoskeletal pain programs run by therapists: RTM, musculoskeletal.
Asthma or COPD with inhaler adherence sensors: RTM, respiratory, though oxygen saturation monitoring would be RPM.
Behavioral health programs using a qualifying digital CBT device: RTM, cognitive behavioral therapy.

What would the 2027 proposals change for RTM?

The CY2027 proposed rule (91 FR 43842) would bring RTM closer to RPM:

RTM would be limited to established patients, as RPM already is.
Both would need a face-to-face initiating visit, in person or by telehealth, at which the service is discussed.
Both would be paid only when clinical staff are direct employees of the billing practitioner or practice.
CMS sought comment on collapsing the remote monitoring code families into four G-codes, two for RPM and two for RTM.

The final rule is expected in early November 2026. See the 2027 direct employee proposal.

Does documentation differ between the two?

The structure is the same, but RTM charts carry an extra burden of explanation. Because RTM data can be patient reported, the record should show how the data reached you (which device, which entries were reported by the patient and which were captured automatically) and how the treating clinician used it to adjust the therapy plan. For therapists billing RTM, the plan of care should name the monitoring and its purpose. For RPM, the record should show the transmitted readings, the days counted, and the clinical decisions they informed.

Decisions to make before launching either

Which patients, which data, and which clinician will act on it.
Whether the device you want meets the section 201(h) definition and fits the RTM category you intend to bill.
Who on staff performs the monthly interactive communication, and whether they are your employees.
How you will avoid enrolling one patient in both programs.

Our RPM Program Setup ($5,950) covers RPM and RTM programs. See the setup checklist and pricing. Coding questions go to White Glove Medical Billing.

Common questions

Can physical therapists bill RPM?

Generally no, because RPM treatment management codes are evaluation and management services that physical therapists cannot furnish. CMS created RTM in part so that practitioners like physical therapists can bill for remote monitoring of therapy.

Can RTM use patient-reported data?

Yes. CMS explained in its CY2022 final rule that RTM data can be patient reported as well as digitally uploaded, while RPM data must be physiologic and digitally uploaded. Both still require a device that meets the FDA definition of a device.

Can I bill RPM and RTM for the same patient?

Not concurrently. CMS said practitioners may bill RPM or RTM, but not both, alongside other care management services such as chronic care management, and CPT bars reporting RTM and RPM treatment management together.