RTM Treatment-Management Time: What Counts Toward 10/20/40 Minutes

RTM treatment-management time is the time a billing practitioner — or clinical staff furnishing the service under appropriate supervision — spends reviewing a patient's transmitted recovery data, adjusting or reinforcing the monitoring/exercise plan based on that data, and coordinating care tied to the RTM episode, plus the duration of the required interactive call itself, all combined into a single running total for the calendar month. That total is what determines whether the month bills at 98979 (10–19 minutes), 98980 (20 minutes or more), or adds 98981 units on top of 98980 for each additional full 20-minute block. Clerical tasks, scheduling, and time on a separately billed visit don't count toward it.

What counts toward the total

The treatment-management codes pay for the ongoing work of managing a patient's RTM data between visits — not just the call. In practice, that's:

• Reviewing transmitted data and trends — pain scores, adherence, function, range of motion — logged through the monitoring program.
• Adjusting or reinforcing the care plan based on what that data shows, whether that's escalating a concern, modifying the home program, or confirming the patient is on track.
• Non-face-to-face care coordination tied to the RTM episode — for example, communicating with the referring surgeon or another member of the care team about the patient's monitored status.
• The interactive call itself. Its duration is part of the same total, not an add-on to it — a 12-minute call plus 10 minutes of prior data review is 22 minutes toward 98980, not 22 "management" minutes and a separate call credit.

Total management time is portal review time plus call duration, combined into one number — not two separate buckets.

What doesn't count

• Clerical or scheduling tasks — booking the next appointment, filing paperwork, updating contact info.
• General practice administration not tied to this specific patient's monitored data.
• Time on a separately billed face-to-face visit — an in-person or telehealth E/M or therapy visit bills under its own code; don't double-count that time into the RTM total.
• Work performed before the RTM episode and consent were in place — the episode has to be active for the time to count toward it.
• A voicemail or one-way message — as with the interactive-call requirement itself, one-way contact doesn't qualify as the synchronous communication, though genuine data review can still count as management time even when it isn't the call.

How the minutes stack across a calendar month

Who can log the time

RTM treatment-management services are care-management services billable under general supervision, and in private practice a PTA's or OTA's time can count toward the total under the general supervision of the supervising PT or OT. Whether an assistant furnished the service can also trigger the CQ/CO de minimis modifier and an associated payment reduction when the assistant's contribution exceeds the de minimis standard. Supervision expectations can vary by MAC in edge cases, and incident-to billing by an NP or PA carries its own supervision rules — confirm with your biller before assuming a given staff member's logged time is billable as-is.

Documenting it so it holds up

For an auditor, a total minute count with nothing behind it isn't enough. Capture, per entry: the date, duration, a short note on what was reviewed or done (the data reviewed, the plan change, the coordination), and — for the interactive call specifically — the same call-documentation elements covered in our guide to the call requirement. Entries should tie to the same patient and calendar month you're billing, and the running total should be visible before you certify the month, not reconstructed from memory afterward.

FAQ