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What counts as billable RTM review time

The time that counts is wider than most providers assume — including calls to a PCP, time on hold with a vendor, and deciding the plan is working and changing nothing.

Written by Paul Yerhot

Most providers count far less than they are entitled to.

The treatment-management codes (98979, 98980, 98981) pay on time accrued across a calendar month. The single most common reason a clinic under-bills them is not laziness — it is that providers assume only the obvious minutes count. They count more than you think.


What counts

What you did

Counts?

Read a patient's message and replied to them

Yes

Read a message, then spent five minutes updating their home exercise program

Yes — all of it, not just the reading

A message prompted you to call the patient's primary care physician, or a colleague

Yes

A message prompted a conversation with the covering PT or PTA who saw them last

Yes

A message prompted you to call an equipment vendor — including the time on hold

Yes. One provider logged 15 minutes of hold time

A message prompted you to contact the patient's personal trainer

Yes

You reviewed the data, decided the plan is working, and changed nothing

Yes — deciding not to act is still clinical review

The patient reported good news and you responded to it

Yes — progress counts exactly as much as problems


The one rule that decides it

For review and follow-up work, the thing that set it in motion has to have come from the patient's RTM responses. If the patient told you something at their visit and that prompted you to call their physician, that is not new information from monitoring — so it is not RTM review time.

The reasoning is straightforward: the codes exist to pay for reacting to between-visit data. If there was no between-visit data point, there is nothing to react to.

A synchronous interaction works differently. You do not need a message to prompt it — you can call a patient to discuss how they are doing whenever you judge it useful, and log it.


Close the loop in writing — it helps the patient and it makes the record clear

When a patient's message leads you to do something on their behalf, tell them so in SaRA before you do it. "Thanks for flagging that — I'm going to reach out to your trainer today about the loading, and I'll let you know what we land on."

This is good care first: the patient learns their message produced action, which is the single biggest driver of whether they keep replying. It also happens to make the sequence legible later — the message, your acknowledgment, and the work that followed all sit in one place.

The line that matters. Close the loop on work you were genuinely going to do because the patient's message warranted it. Do not send a message in order to manufacture a reason to bill — the clinical decision has to stand on its own, and the note has to describe care you would defend to a reviewer regardless of the code. If the work would not have happened without the billing, it should not happen.


You do not have to track this by hand

  • Time spent reading and responding inside SaRA is captured automatically. There is no timer to start.

  • What you add manually is the work that happened outside the app — the phone call, the HEP rebuild, the conversation with a colleague — and the synchronous interaction.

  • You can edit an auto-captured entry after the fact to add time, so you are never forced to log in the moment.


Two guardrails

  • Time logged to RTM cannot also be counted toward a timed therapeutic code. One minute belongs to one thing.

  • RTM time logged during an in-person visit must not exceed the total visit time documented in your EMR.

How the logged time turns into codes is in RTM CPT codes & billing thresholds.

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