# Can PTs, OTs, and SLPs Bill RTM? Yes — Here's How

By Sulo Team (Pediatric therapy & RTM) · Published 2026-07-16 · Updated 2026-08-06
Canonical: https://sulomotion.com/blog/can-pts-ots-slps-bill-rtm/

**The bottom line:** Yes. RTM was deliberately designed so physical therapists, occupational therapists, and speech-language pathologists can bill it directly — no physician involvement required. PTs and OTs bill the full stack: CPT 98975, 98977, 98980, and 98981 under a therapy plan of care with the GP or GO modifier, worth $105.55 per patient per month on the recurring pair. SLPs bill RTM too (GN modifier), but anchor on 98975 and the treatment-management codes — no device-supply code covers speech, language, or swallowing monitoring. One catch: Medicare won't pay RTM to both PT and OT for the same beneficiary.

- RTM codes are 'general medicine' codes, so therapists bill them in their own right — unlike RPM.
- Claims carry GP (PT), GO (OT), or GN (SLP), and must sit under a therapy plan of care whose certification is current — a lapsed plan of care makes RTM unpayable even in a month with no visits.
- SLPs can bill setup (98975) and treatment management (98980/98981) but generally not the device-supply codes — ASHA's guidance says the body-system-specific codes 'may not apply' to SLP services.
- Medicare will not pay RTM to both PT and OT for the same beneficiary. One discipline has to own it.
- The therapist must be licensed where the patient is physically located at the time of service — not where the clinic is.

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## Why can therapists bill RTM when they can't bill RPM?

**Because RTM was written as a set of general-medicine codes, not evaluation-and-management codes.** RPM's E/M classification restricts it to physicians, NPs, and PAs. When CMS introduced RTM in 2022, the explicit intent was to give practitioners who *can't* bill E/M — physical therapists, occupational therapists, speech-language pathologists — a remote-monitoring program of their own.

So the answer to the headline question isn't a loophole or a gray area. Therapists are the primary intended billers of RTM. The full background is in [RTM vs RPM: the difference for therapy clinics](/blog/rtm-vs-rpm/).

## What can each discipline bill?

All three disciplines use the same code family — [98975, 98977, 98980, and 98981](/blog/rtm-cpt-codes-explained/) — with one nuance around the device-supply code.

### Physical therapists (PT)

The cleanest fit. A home exercise program is musculoskeletal monitoring, which is exactly what **98977** covers. A typical PT patient pairs 98977 (16+ days of logged data) with 98980 (20+ minutes of monthly review), worth **$105.55/month** combined at 2026 national rates.

Musculoskeletal is also broader than it sounds. It covers pelvic floor work, urinary and bowel conditions, vertigo where the origin is musculoskeletal, and monitoring that tracks things like bathroom frequency, sleep quality, and pain levels alongside exercise adherence.

### Occupational therapists (OT)

Same structure as PT: home programs targeting motor skills, strength, and function fall under musculoskeletal monitoring, so **98977 + 98980** is the standard pattern, with 98975 at setup.

### Speech-language pathologists (SLP)

SLPs can bill RTM — every RTM code sits on the Medicare fee schedule for SLPs, billed with the GN modifier. But the billable stack is narrower than PT/OT, because the device-supply codes are **body-system specific** and none of them describes speech, language, voice, or swallowing. The full breakdown is in the next section.

## The SLP fine print: what's billable and what isn't

The device-supply codes cover exactly three monitoring categories: **respiratory** (98976, and 98984 for 2–15 days), **musculoskeletal** (98977, and 98985 for 2–15 days), and **cognitive behavioral therapy** (98978, and 98986 for 2–15 days). There is no speech, language, voice, swallowing, or cognitive-communication category — and ASHA's guidance is direct about what that means: the device-supply codes "may not apply to speech-language pathology related services," and clinicians should not report them "for other devices or systems not described here."

Two questions come up constantly, so here are the straight answers:

**"Swallowing is muscular — can't an SLP bill the musculoskeletal code (98977) for a dysphagia home program?"** Not as a default, no. The descriptor says *monitoring of the musculoskeletal system*, which is how CMS and the AMA describe PT/OT-style movement and exercise monitoring — not oropharyngeal function. Billing 98977 for a speech or swallowing program stretches the descriptor past what ASHA endorses, and it's exactly the kind of claim that invites recoupment in an audit.

**"Does that mean SLPs can't run an RTM program at all?"** No — and this is the part most articles miss. ASHA explicitly confirms that **98980 and 98981 may still be reported for RTM treatment management even when the monitoring device isn't described by any device-supply code.** The management codes have no body-system restriction. So the working SLP stack is:

| Code | What it covers | 2026 national rate |
|------|----------------|--------------------|
| 98975 | One-time setup and patient/family education | $21.71 |
| 98980 | First 20 minutes of monthly management + interactive communication | $54.11 |
| 98981 | Each additional 20 minutes | $41.42 |
| 98979 | 10–19-minute months (new for 2026) | $26.39 |

That's **$54.11/month per patient** on the standard 20-minute pattern — versus $105.55 for PT/OT, because the $51.44 device-supply component drops out. Still real revenue for follow-up work SLPs already do unpaid; just budget the program on management-code math, not the PT numbers.

One narrow exception: if what's being monitored is genuinely **respiratory** — breath support in voice therapy, respiratory-swallow coordination — 98976/98984 may legitimately fit. That's a clinical-fit-plus-payer-confirmation call, not a default, and the documentation needs to show respiratory data, not exercise adherence relabeled.

Everything else — GN modifier, plan of care, the 20-minute management threshold, the device requirement — applies to SLPs exactly as it does to PTs and OTs. (The 16-day data threshold governs the device-supply codes, so it's largely moot for an SLP stack that doesn't include one.)

On that device requirement, one correction worth making because it's widely overstated: the software must **meet the FDA definition** of a medical device, or software as a medical device, under section 201(h) of the Food, Drug, and Cosmetic Act. It does **not** need to be FDA-approved, cleared, or registered — those are different and much higher bars, and a platform that isn't registered can still be perfectly compliant. If you're unsure about a specific tool, ask the vendor for documentation confirming it meets the definition.

## What modifiers and documentation do RTM claims need?

Three requirements sit on every therapist-billed RTM claim:

1. **The therapy modifier.** GP (physical therapy), GO (occupational therapy), or GN (speech-language pathology) — RTM codes furnished by therapists are "sometimes therapy" services and always carry the discipline modifier. Eight RTM codes carry that designation: the original five from CY2022, plus 98979, 98984 and 98985 added effective January 1, 2026.
2. **A current plan of care.** RTM isn't freestanding; the monitoring must relate to an established therapy plan of care, and the certification or recertification must be **current** — not merely on file. This is the quiet denial driver, because RTM can run through stretches with no in-person visits, and a plan of care can lapse without anyone noticing. It also works the other way: a patient can stop in-person visits and continue RTM briefly, through a discharge transition for instance, as long as the plan of care is still valid and any required authorization covers those dates.
3. **Defensible documentation.** Timestamped evidence of which 16 days qualified, how the 20 minutes accumulated — CMS expects login sessions logged to the minute and second — and the date, duration, and content of each interactive communication, plus any program changes you made in response. The thresholds are unforgiving; the [16-day and 20-minute rules](/blog/new-2026-rtm-rules/) have their own breakdown.

## Does RTM count as a visit?

**No — and the confusion costs clinics both ways.** Teams under-enroll because they assume RTM will burn through a patient's authorized visits, and payers occasionally deny for the same wrong reason. Four rules are worth knowing precisely:

- **RTM is not telehealth.** A telehealth session counts as a visit under outpatient therapy. RTM is a separate category of service with its own codes and rules, and it doesn't.
- **It doesn't count as a visit**, and it doesn't count toward the **10-visit progress report requirement**.
- **It does count toward the annual therapy dollar threshold**, so it belongs in threshold tracking even though it isn't a visit.
- **MPPR doesn't apply.** RTM codes aren't subject to the multiple procedure payment reduction when billed alongside same-day therapy services.

Some commercial and Medicaid payers have nonetheless counted RTM against authorized visit limits or benefit maximums. That's an error, not a policy, and APTA and AOTA are both working the issue — worth appealing rather than absorbing.

## Can assistants furnish RTM services?

**Yes** — and RTM got there before the rest of outpatient therapy did. The CY 2024 Physician Fee Schedule final rule allowed RTM services specifically to be furnished by PTAs and OTAs under the **general supervision** of a PT or OT in private practice, effective January 1, 2024. The CY 2025 final rule then extended general supervision to *all* outpatient therapy services in private practice, effective January 1, 2025. Either way the practical rule today is the same: the supervising therapist must be available, typically by phone, but not physically in the building — so an assistant can handle routine data review and family check-ins with the therapist directing care. Many summaries date RTM's general-supervision policy to 2025; for RTM it has been in force a year longer than that.

The assistant modifiers follow a rule that trips people up. The de minimis standard — and therefore **CQ** (PTA) and **CO** (OTA) — applies to exactly four RTM codes: **98975, 98979, 98980 and 98981**. It applies to none of the six device-supply codes. The reason is logical once you see it: a device-supply code pays for the *patient* logging in and transmitting data, so there's no assistant service to adjust. Append CQ or CO to the setup and management codes when an assistant furnished the work in whole or in part; never to 98976, 98977, 98978, 98984, 98985 or 98986.

## Do commercial payers and Medicaid cover therapist-billed RTM?

**Increasingly, but unevenly.** Medicare coverage is nationwide and rate-published. Medicaid varies by state, and commercial plans vary by contract — some follow Medicare's RTM policy closely, others limit codes or require prior authorization. Before enrolling a caseload, verify your top three payers; for pediatric clinics, that usually means your state Medicaid program plus the dominant regional commercial plans. Rates live on the [CMS fee schedule search](https://www.cms.gov/medicare/physician-fee-schedule/search).

## The bottom line for your clinic

If your clinic prescribes home programs and follows up on them — and every therapy clinic does — you're already doing the clinical half of RTM without billing for it. The gap is operational: consent, logging, threshold tracking, and claims — walked through end to end in [how to start an RTM program](/blog/how-to-start-rtm-program/). That's a solvable systems problem, and the [2026 threshold rules](/blog/new-2026-rtm-rules/) explain exactly which code each month's data earns. For the full picture including a reimbursement estimator, see the [complete RTM guide](/what-is-remote-therapeutic-monitoring).

## Frequently asked questions

### Do therapists need a physician's order to bill RTM?

RTM follows the same rules as the rest of therapy care: services are furnished under the therapist's plan of care, subject to your state's practice act and payer requirements. No separate physician oversight of the monitoring itself is required.

### Can physical therapist assistants (PTAs) do RTM work?

Yes. PTAs and OTAs can furnish RTM services under general supervision in private practice — the supervising therapist must be available but not physically present. For RTM specifically this dates to the CY 2024 final rule, effective January 1, 2024; the CY 2025 rule later extended general supervision to all outpatient therapy services in private practice, effective January 1, 2025. The CQ/CO assistant modifiers apply per normal Medicare rules.

### Which RTM device code should an SLP use?

Usually none. The device-supply codes only cover three body systems — respiratory (98976), musculoskeletal (98977), and cognitive behavioral therapy (98978) — and ASHA's guidance is that they 'may not apply to speech-language pathology related services.' SLPs bill 98975 at setup plus 98980/98981 for monthly treatment management, which ASHA confirms can be reported even when the monitoring device doesn't match any device-supply category.

### Can an SLP bill 98977 for swallowing or oral-motor exercises?

No — not as a default. Swallowing involves muscles, but a dysphagia or speech home program isn't 'monitoring of the musculoskeletal system' as the code descriptor defines it, and ASHA explicitly warns against reporting device-supply codes for systems not described in the descriptors. The defensible SLP claim is 98975 plus 98980/98981.

### Does RTM billing count against Medicare therapy thresholds?

Two different questions, with two different answers. RTM does count toward the annual therapy dollar threshold, so include it in your threshold tracking. But RTM is not a visit: it doesn't consume an authorized visit, it doesn't count toward the 10-visit progress report requirement, and MPPR doesn't apply to RTM codes. If a payer counts RTM against a visit limit, that's an error worth appealing.

### Does the therapist need to be licensed in the patient's state?

Yes. The treating therapist or assistant must be licensed in the state where the patient is physically located at the time of service — which, for a remote program, isn't always the state your clinic sits in. The PT Compact helps: as of January 2026, 35 states actively issue and accept compact privileges, five have enacted legislation without yet issuing (Connecticut, Kansas, Maine, Nevada, Rhode Island), and three have introduced it without enacting (Illinois, Massachusetts, Michigan). Check each state for additional rules governing providers not physically present there.

### Can PT and OT both bill RTM for the same patient?

No, not under Medicare. CMS does not allow concurrent RTM payment to both disciplines for the same beneficiary, even across separate episodes of care with different diagnoses. One discipline has to own it — decide which before enrolling. APTA and AOTA are both lobbying CMS to relax this.

### Can RTM be billed outside private practice?

Yes. RTM works in hospital outpatient departments and rehab agencies as well as private practice. Professional claims on the CMS-1500 use place of service 11 for a clinic or office and 12 for the patient's home when the practice has no physical office. Institutional claims on the UB-04 use revenue code 420 for physical therapy, 430 for occupational therapy, and 440 for speech-language pathology.


## Sources

1. [CMS — 2026 Physician Fee Schedule Relative Value Files (RVU26A/RVU26C; source for all rates quoted here)](https://www.cms.gov/medicare/payment/fee-schedules/physician/pfs-relative-value-files)
2. [CMS — Therapy Code List: 2026 Annual Update (MM14250)](https://www.cms.gov/files/document/mm14250-therapy-code-list-2026-annual-update.pdf)
3. [APTA — Practice Advisory: Remote Therapeutic Monitoring Codes Under Medicare (updated January 2026)](https://www.apta.org/your-practice/payment/medicare-payment/rtm-codes-practice-advisory)
4. [ASHA — Coding and Payment of Communication Technology-Based Services (RTM guidance for SLPs)](https://www.asha.org/practice/reimbursement/medicare/coding-and-payment-of-communication-technology-based-services/)
5. [ASHA — 2026 Medicare Fee Schedule for Speech-Language Pathologists (PDF)](https://www.asha.org/siteassets/reimbursement/2026-medicare-fee-schedule-for-speech-language-pathologists.pdf)
6. [ASHA — Speech-Language Pathology CPT and HCPCS Code Changes for 2026](https://www.asha.org/practice/reimbursement/coding/new_codes_slp/)
7. [CMS — Physician Fee Schedule (payment policy overview)](https://www.cms.gov/medicare/payment/fee-schedules/physician)
8. [CMS — Physician Fee Schedule Search (current RTM rates by locality)](https://www.cms.gov/medicare/physician-fee-schedule/search)
9. [AMA — CPT overview and code maintenance](https://www.ama-assn.org/practice-management/cpt)

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