Who Can Bill RTM? Provider Eligibility Explained (2026)

Q: Who can bill RTM?

Physicians and other qualified health care professionals (NPs, PAs, clinical nurse specialists) can bill RTM directly under their own NPI, or have clinical staff furnish it incident-to their supervision. Physical therapists, occupational therapists, and speech-language pathologists can also bill RTM, but they bill it under an active therapy plan of care with a discipline-specific modifier (GP for PT, GO for OT, GN for SLP) rather than incident-to.

Q: Can a nurse practitioner or physician assistant bill RTM?

Yes. NPs and PAs are qualified health care professionals under CMS's RTM policy and can bill the RTM codes directly under their own NPI, subject to their state's scope-of-practice rules. RTM services can also be furnished incident-to a supervising physician or NPP by clinical staff, billed under that supervising provider's NPI.

Q: Do physical therapists bill RTM the same way as physicians?

No. Physicians and NPPs bill RTM directly under their own NPI, or incident-to. Physical therapists (and OTs, SLPs) bill RTM under an active therapy plan of care and append a discipline-specific therapy modifier — GP for PT, GO for OT, GN for SLP — to each RTM line. The underlying CPT codes and thresholds are the same; the billing pathway and modifier differ by credential.

Q: Can two different providers bill RTM for the same patient in the same month?

No. Only one practitioner may bill the RTM device-supply and treatment-management codes for a given patient in a given 30-day period — sometimes called the one-biller rule. This matters most when a patient is followed by both an operating surgeon and a physical therapist; the practice has to designate a single biller for that period, not split the codes between the two.

Q: Does RTM require physician supervision for non-physician staff?

Remote monitoring services like RTM are designated care management services billable under general supervision — the supervising practitioner doesn't need to be physically present while clinical staff furnish the service incident-to. Therapy-billed RTM (PT/OT/SLP) follows the supervision rules for therapy assistants under general supervision in private practice; confirm current requirements with your MAC and state practice act.

On this page

The short answer Physicians & NPPs PT, OT & SLP Eligibility at a glance Supervision rules The one-biller rule FAQ

Key takeaways

Physicians, NPs, and PAs can bill RTM directly under their own NPI, or have clinical staff furnish it incident-to their supervision.
PTs, OTs, and SLPs bill RTM under an active therapy plan of care with a discipline modifier — GP (PT), GO (OT), or GN (SLP) — not incident-to.
The underlying CPT codes and thresholds don't change by credential — only the billing pathway and modifier do.
Only one practitioner may bill RTM for a given patient in a given 30-day period, regardless of credential — the one-biller rule.

Physicians and other qualified health care professionals — nurse practitioners, physician assistants, clinical nurse specialists — can bill RTM directly under their own NPI, or have clinical staff furnish it incident-to their supervision. Physical therapists, occupational therapists, and speech-language pathologists can also bill RTM, but they do it under an active therapy plan of care with a discipline-specific modifier rather than incident-to. Same six CPT codes, same day and minute thresholds — the pathway and the modifier are what change by credential.

As of the CY2026 Medicare Physician Fee Schedule. General educational information, not billing or legal advice. Scope-of-practice rules vary by state, and payer-specific eligibility can differ from traditional Medicare — confirm with your biller and your state practice act.

Physicians and non-physician practitioners

Physicians, nurse practitioners, physician assistants, and clinical nurse specialists are all qualified to furnish and bill RTM. Two pathways apply:

Direct billing. The physician or NPP personally furnishes the service (or supervises its clinical elements closely enough to bill under their own NPI) and bills RTM under their own credentials.
Incident-to billing. Clinical staff — often a medical assistant or nurse — carry out day-to-day elements of the RTM service under the general supervision of a physician or NPP, and the service bills under the supervising practitioner's NPI at that practitioner's rate. This is the common model in a busy surgical or primary-care practice where the surgeon or physician isn't personally reviewing every data point.

Remote monitoring services like RTM are designated as care management services, which is what allows the general supervision standard — the supervising physician or NPP doesn't need to be on-site while incident-to staff furnish the service, only generally available.

Physical therapists, occupational therapists, and SLPs

Therapists bill RTM differently, and this is the distinction that trips practices up most. A PT, OT, or SLP doesn't bill RTM incident-to a physician — they bill it directly under their own NPI, but only under an active therapy plan of care, with a discipline-specific therapy modifier appended to each RTM line:

GP — physical therapy plan of care
GO — occupational therapy plan of care
GN — speech-language pathology plan of care

The plan of care has to be current — generally recertified at least every 90 days — and the RTM service has to sit within that plan, not as a freestanding service alongside it. Therapy-billed RTM is also where the CQ (PTA) and CO (OTA) assistant modifiers can come into play if a therapy assistant furnishes 10% or more of a given service line — see the full GP/CQ modifier guide for the worked examples.

Same CPT codes, same 98975–98981 ladder, same day and minute thresholds. What changes for a therapist is the modifier and the fact that the service has to sit inside an active plan of care rather than under incident-to supervision.

Eligibility at a glance

Credential	Bills RTM how	Modifier	Key requirement
Physician (MD/DO)	Directly, under own NPI	None RTM-specific	Standard documentation of the service furnished
NP / PA / clinical nurse specialist	Directly, under own NPI, or incident-to a physician	None RTM-specific	State scope-of-practice compliance
Clinical staff (MA, nurse)	Incident-to a supervising physician/NPP	None RTM-specific	General supervision by the billing practitioner
Physical therapist	Directly, under own NPI, under a therapy plan of care	`GP`	Active, current plan of care
Occupational therapist	Directly, under own NPI, under a therapy plan of care	`GO`	Active, current plan of care
Speech-language pathologist	Directly, under own NPI, under a therapy plan of care	`GN`	Active, current plan of care

Underlying CPT codes (98975–98981) and thresholds are the same across every row — see the full 2026 RTM CPT codes guide. Confirm state scope-of-practice rules and payer-specific credentialing before billing.

Supervision rules, briefly

RTM's designation as a care management service is what unlocks general supervision for incident-to billing — the supervising physician or NPP has to be generally available, not physically present, while clinical staff furnish the service. On the therapy side, physical therapist assistants and occupational therapy assistants can generally furnish therapy services — including RTM under a plan of care — under general supervision of the PT or OT in a private-practice setting. An unenrolled or newly credentialed PT or OT may face a stricter direct-supervision standard in some contexts; confirm current requirements with your MAC.

One rule that applies no matter who's billing: the one-biller rule

Regardless of credential, only one practitioner may bill the RTM device-supply and treatment-management codes for a given patient in a given 30-day period. This matters most for a mixed surgical-and-therapy practice, where a patient recovering from surgery might plausibly be monitored by both the operating surgeon and an in-house PT in the same window. The practice has to designate a single biller for that period — see the full breakdown of billing RTM when two providers are involved for how that designation actually works.

Track eligibility the same way you track everything else.

BoneArc records which provider is the designated RTM biller for each patient and period, alongside the consent, data-days, review time, and call attestation that make the month billable.

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FAQ

Who can bill RTM?

Physicians and qualified NPPs (NPs, PAs, clinical nurse specialists) can bill RTM directly or incident-to. PTs, OTs, and SLPs can also bill RTM, under an active therapy plan of care with a discipline modifier (GP/GO/GN) rather than incident-to.

Can a nurse practitioner or physician assistant bill RTM?

Yes — NPs and PAs are qualified health care professionals under CMS's RTM policy and can bill directly under their own NPI, subject to state scope-of-practice rules. RTM can also be furnished incident-to a supervising physician or NPP.

Do physical therapists bill RTM the same way as physicians?

No. Physicians and NPPs bill directly or incident-to. PTs (and OTs, SLPs) bill under an active therapy plan of care with a discipline-specific modifier (GP for PT). The CPT codes and thresholds are identical; the pathway and modifier differ.

Can two different providers bill RTM for the same patient in the same month?

No — only one practitioner may bill the RTM codes for a given patient in a given 30-day period. This is the one-biller rule, and it matters most when a surgeon and a PT are both monitoring the same recovering patient.

Does RTM require physician supervision for non-physician staff?

RTM is billable under general supervision as a care management service — the supervising practitioner doesn't need to be physically present. Therapy-billed RTM follows general-supervision rules for assistants in private practice; confirm current requirements with your MAC and state practice act.

Sources & verification. Physician/NPP direct and incident-to billing eligibility for RTM, and the general-supervision standard for care management services, reflect CMS RTM policy under the CY2026 Medicare Physician Fee Schedule final rule (CMS-1832-F, RTM discussion 90 FR 49394–49404) and 42 CFR 410.26(b)(5) (remote monitoring designated as a care management service billable under general supervision), consistent with this repository's verified payer-rules/medicare-baseline.json supervision record (status: verified, retrieved 2026-07-03). The therapy modifier requirement (GP/GO/GN) for therapist-rendered RTM and the CQ/CO assistant de-minimis policy reflect MLN MM14250 / Transmittal R13431CP (2026 therapy code list), also recorded in that same verified source. The one-biller-per-30-day-period rule reflects 88 FR 78883 and MLN901705 p.13. General/direct PTA-OTA supervision in private practice reflects 88 FR 78882 and 88 FR ~78990 (permanent policy). A direct re-fetch of cms.gov, govinfo.gov, and the eCFR was attempted for this article on 2026-08-16 and blocked by this environment's outbound network proxy; the citations above are drawn from this repository's already-verified canonical payer-rules record rather than a fresh guess, and no new dollar figure, day threshold, or minute threshold is introduced by this article — see the 2026 RTM CPT codes guide for current rates. Educational information, not billing or legal advice — confirm current requirements with your MAC and your state's practice act before billing.