RTM CPT 98978: Cognitive Behavioral Therapy Device Supply 

CPT 98978 is the Remote Therapeutic Monitoring device-supply code for cognitive behavioral therapy monitoring: it covers the transmission of patient-reported and device-collected data related to a cognitive-behavioral therapy plan over a defined monitoring period, billed once that period's data threshold is met, separate from the time-based treatment-management codes.

This page provides general educational information about CPT and RTM billing codes. It is not coding advice, a guarantee of reimbursement, or a substitute for your own compliance review. Payer coverage and documentation requirements vary by plan and can change — verify current requirements with CMS, your Medicare Administrative Contractor, and each payer before billing.

Why This Code Matters for Concussion and Cognitive-Health Practices

Most neurology, neurosurgery, sports-medicine, and orthopedic practices treating concussion, persistent post-concussive symptoms, or related cognitive and mental-health sequelae already generate the underlying clinical signal this code is meant to reimburse: patients report symptoms, mood, sleep, and cognitive function between visits, whether through a phone call to the office, a portal message, or a structured check-in. What's typically missing isn't the clinical data — it's a structured, device-based data-transmission pathway and the associated billing. 98978 is the code built for exactly that gap, and it is commonly under-billed in concussion and cognitive-care settings relative to how much between-visit monitoring these practices already do informally.

What 98978 Covers

98978 is the device-supply component of the RTM code family, specifically for the cognitive behavioral therapy monitoring category (the RTM equivalent of the respiratory-system code 98976 and the musculoskeletal-system code 98977). It represents the technical/supply side of RTM — the device or platform that captures and transmits patient data — as distinct from the clinical time spent reviewing and acting on that data, which is billed separately under 98980/98981 (or the newer 98979, discussed below).

Effective January 1, 2026, the descriptor for 98978 was revised to specify that it covers 16–30 days of data within a 30-day period, rather than simply "16 days or more." This narrows the code to a defined upper bound and pairs it with a new shorter-duration counterpart (98986, discussed below) for lower-engagement monitoring windows.

What Qualifies as "The Device"

RTM device-supply codes require that data be collected via a medical device as defined for RTM purposes — broadly, software or a connected instrument that records or is used to input patient data related to a therapy plan, rather than a simple communication tool. In practice, for cognitive-behavioral-therapy monitoring this generally means a structured digital instrument or platform through which the patient reports symptoms, mood, cognitive complaints, or completes standardized assessments on a defined cadence, and where that data is captured and transmitted to the treating practice — not an unstructured phone call or a one-off email. Practices should confirm their specific platform and workflow meet current CMS device-criteria guidance before billing, since RTM device definitions and enforcement expectations can be refined year to year.

What Data Has to Be Transmitted

The core requirement is 16–30 days of data within a 30-day period for standard-duration 98978 billing. This means the patient must engage with the monitoring instrument — completing check-ins, symptom scales, or assessments — on enough distinct days within that window to meet the threshold, and that engagement has to be captured and transmitted through the device/platform, not simply documented from memory at the next visit. Practices billing 98978 should be able to show, from the platform's own records, which days within the 30-day period data was received.

How 98978 Differs from 98980/98981 and 98979

This distinction is one of the most common sources of confusion in RTM billing, and it matters:

• 98978 — device-supply code. Billed once the data-transmission threshold (16–30 days) is met within a 30-day period. It reflects the technology and data-capture side of RTM, not clinician time.
• 98980 — RTM treatment management, first 20 minutes of clinical staff/physician/QHP time per calendar month, and requires at least one real-time interactive communication with the patient or caregiver during that month.
• 98981 — add-on to 98980, each additional 20 minutes of treatment-management time in the same calendar month.
• 98979 (new for 2026) — a lower-threshold treatment-management code covering the first 10–19 minutes of qualified time per calendar month, for months where clinical engagement falls short of the 20-minute threshold 98980 requires, but still includes at least one real-time interactive communication.

98978 and the treatment-management codes are billed independently: 98978 reflects that data was collected and transmitted; 98980/98981 or 98979 reflect that a clinician spent time reviewing that data and interacting with the patient. A practice can bill 98978 in a given month without any treatment-management code if the data threshold was met but no qualifying clinical time/communication occurred — though from a care-quality standpoint, monitoring without a clinician acting on the data is generally the exception, not the target workflow.

Short-Duration Counterpart: 98986

New for 2026, CPT 98986 is the shorter-duration device-supply code for cognitive behavioral therapy monitoring, covering 2–15 days of data within a 30-day period — for patients whose engagement doesn't reach the 16-day threshold 98978 requires. This closes what CMS and AMA described as an "all-or-nothing" billing cliff, where a patient who engaged meaningfully but briefly generated no billable device-supply code at all. Only one device-supply code — 98978 or 98986, not both — may be billed per patient per 30-day period.

Who Can Bill 98978

RTM billing-practitioner eligibility is statutorily limited to physicians and other qualified health care professionals, along with physical therapists, occupational therapists, and speech-language pathologists (and, for the new 2026 codes, therapy-modifier rules apply when those therapy disciplines furnish the service). CMS reaffirmed in the CY2026 rule that it declined to extend RTM billing eligibility to pharmacists or dietitians. The device-supply itself is typically billed under the ordering/supervising practitioner's NPI, consistent with how existing RTM device-supply codes (98975–98977) are billed.

Documentation Requirements

To support a 98978 claim, documentation should generally establish:

• That an RTM device/platform meeting CMS's device criteria was used, tied to a documented cognitive-behavioral-therapy plan of care.
• The specific days within the 30-day period on which qualifying data was received (supporting the 16–30 day threshold).
• That the monitoring relates to an active therapy plan — RTM is not billed for passive or incidental data collection unconnected to a treatment plan.
• Consistency between the device-supply period claimed and the calendar-month structure used for any associated treatment-management billing (98979, 98980/98981).

Common Denial Reasons

• Billing 98978 without at least 16 days of data actually transmitted within the 30-day period (falling short of the threshold; 98986 may apply instead).
• Billing both 98978 and 98986 for the same patient in the same 30-day period — only one device-supply variant is allowed.
• No documented connection between the monitoring data and an active cognitive-behavioral-therapy plan of care.
• Device or platform not meeting RTM's device-criteria definition (e.g., unstructured communication treated as monitoring data).
• Billing by a practitioner type not currently eligible for RTM under Medicare.

Worked Example Scenario

A sports-medicine physician manages a patient with persistent post-concussive symptoms, including anxiety and sleep disruption consistent with a cognitive-behavioral-therapy monitoring plan. The patient completes structured symptom and mood check-ins through a monitoring platform on 19 distinct days over a 30-day period. That data-transmission pattern meets the 16–30 day threshold for 98978. Separately, clinical staff spend 22 minutes that same calendar month reviewing the data and conducting one telephone check-in with the patient, meeting the time and real-time-communication requirements for 98980 plus one additional unit of 98981. In this scenario, the practice may be positioned to bill 98978 for the device-supply component and 98980/98981 for the treatment-management component — subject to the practice's own documentation review and current payer policy.

Related Codes

• RTM 98975 — Initial Setup and Patient Education
• RTM 98980/98981 — Treatment Management
• RTM 98979 — Short-Duration Treatment Management
• CPT 96132 — Neuropsychological Test Evaluation

How Kavera Handles This

98978 is the code the Kavera program was built around. The device is brain training plus the weekly symptom, mood and sleep check-ins, delivered through the platform. Kavera counts the days the patient engaged in each 30-day period and shows you when the 16-day threshold is met. Most concussion practices are already doing informal versions of this work and billing none of it. Self-Serve practices run this with their own staff. On Managed, Juliet Mott's team runs it and bills it under your credentials. Educational, not coding advice. Verify requirements with CMS, your MAC and each payer.

FAQ

Does 98978 require a specific type of device?

It requires a platform or instrument that meets CMS's RTM device-criteria definition — generally software or a connected tool used to record or transmit patient-reported or device-collected data tied to a therapy plan. A single unstructured phone call typically would not qualify; consult current CMS guidance and your own compliance review before billing.

Can I bill 98978 every month for the same patient?

98978 can be billed for each 30-day period in which the 16–30 day data-transmission threshold is met and the monitoring remains tied to an active therapy plan. Ongoing eligibility depends on continued clinical necessity and current payer policy, which practices should verify independently.

What's the difference between 98978 and 98986?

Both are cognitive-behavioral-therapy device-supply codes for RTM; 98978 covers 16–30 days of data in a 30-day period, while 98986 (new for 2026) covers a shorter 2–15 day window. Only one of the two may be billed per patient per 30-day period.

Do I need a real-time call with the patient to bill 98978?

No — the real-time interactive communication requirement applies to the treatment-management codes (98979, 98980/98981), not to the device-supply code 98978 itself, which is based on data transmission.

Who is eligible to bill 98978?

Physicians and other qualified health care professionals, along with physical therapists, occupational therapists, and speech-language pathologists, subject to CMS's RTM eligibility rules. Pharmacists and dietitians are not currently eligible to bill RTM codes under Medicare.