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The RTM Interactive Call Requirement, Explained

The treatment-management codes don’t pay without a documented, real-time call. Here’s exactly what counts, and how to document it so it holds up.

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On this pageWhat the requirement isWhat counts as a callWhat doesn’t countHow to document itOne call, or one per code?

Key takeaways

  • Every treatment-management code (98979 / 98980 / 98981) requires at least one interactive, synchronous communication per calendar month.
  • “Synchronous” means real-time and two-way — a live phone or audio-video conversation, not a message or a portal note.
  • The call must be documented and attested by the billing provider, and its time can count toward the management-time total.
  • Device-supply codes (98975/98977/98985) do not need the call — only the management codes do.
As of the CY2026 Medicare Physician Fee Schedule (final rule CMS-1832-F, effective January 1, 2026). General educational information, not billing or legal advice. Coverage, codes, and payment vary by payer and locality — confirm specifics with your biller.

It's the single most common reason an RTM month gets denied or left unbilled: the treatment-management code requires a real conversation with the patient, and either it didn't happen or it wasn't documented. Daily logs piling up and minutes of chart review feel like they should be enough — but for 98979, 98980, and 98981, they aren't. You need the call.

What the requirement actually is

The RTM treatment-management codes — 98979 (10–19 min), 98980 (20–39 min), and 98981 (each additional 20 min) — each require at least one interactive communication with the patient or caregiver during the calendar month. This is built into the code definitions themselves; it isn't an optional best practice. The device-supply codes (98975, 98977, 98985) carry no such requirement — this gate is specific to the time-based management codes.

What counts as a “synchronous interactive communication”

The key word is synchronous — real-time and two-way. A live telephone call qualifies. A real-time audio-video visit qualifies. The defining feature is that you and the patient are communicating back and forth in the moment.

If it isn't a live, two-way conversation, it doesn't satisfy the requirement — no matter how much other work you did.

What does not count

Those activities can be part of the management work; they just can't be the interactive communication that unlocks the code.

How to document it so it holds up

For an auditor, “we called them” isn't enough. Capture, at minimum: the date of the call, that it was a synchronous, two-way communication, a short clinical summary of what was discussed, the duration (it rolls into your management-time total), and the provider's attestation that it occurred. Tie it to the same patient and month you're billing.

This is exactly the kind of structured record BoneArc captures at the moment of the call — date, duration, summary, communication type, and attestation — instead of leaving you to reconstruct it at month-end.

One call for the month, or one per code?

The requirement is at least one qualifying interactive communication in the calendar month for the management service — not a separate call for 98980 and again for 98981. The minute thresholds determine which tier you reach (10–19, 20–39, 40+); the single documented call satisfies the communication requirement for the management service that month. As always, confirm specifics with your biller and payer.

RTM left on the table is usually a bookkeeping problem, not a coding one.

BoneArc tracks data-days, review time, and the attested call — so the billable work is documented as it happens.

See it on your panel →
Sources & verification. Reflects the 2026 CPT code set and CMS CY2026 Physician Fee Schedule final rule (CMS-1832-F), effective January 1, 2026. Code identities, descriptors, and day/minute thresholds are stated as published; the one national dollar figure given is 98975 = $21.71 (non-facility) — all other amounts vary by MAC, locality (GPCI), and contract and are described as ranges. Educational information, not billing or legal advice — verify against current CMS guidance and your fee schedule.