The surgeon incentive
CMS created the RTM pathway for exactly this scenario. Nobody is showing surgeons the math.
TL;DR
Remote Therapeutic Monitoring (CPT 98975 + 98977 + 98980) pays approximately $115.60 per patient per 30-day protocol cycle to the monitoring clinician. tPEMF devices qualify under the CY2022 PFS final rule. The treating physician bills under their own NPI; the SMS-based outcome-tracking engine provides the documentation automatically. At 30 patients on protocol, that is $3,500 per month in additional practice revenue the surgeon is currently not collecting.
CMS established Remote Therapeutic Monitoring codes in the CY2022 Physician Fee Schedule final rule (effective January 1, 2022). RTM is distinct from Remote Patient Monitoring (RPM): RPM covers physiologic data collection (vital signs, glucose, oxygen saturation); RTM covers monitoring of therapeutic device use and patient-reported outcomes related to a therapeutic regimen. tPEMF devices qualify because they are musculoskeletal therapeutic devices that generate device-use data (session logs) and patient-reported outcome data (pain scores, functional measures) that a treating clinician monitors to guide the therapeutic plan. The 2026 PFS expanded the MSK device supply code set with two new codes (98979, 98985) that increase billing flexibility for shorter or longer monitoring windows.
The standard 30-day RTM cycle for a tPEMF patient uses three codes: 98975 (initial device setup and patient education, $21.71 — billed once per episode), 98977 (device supply, musculoskeletal, 16–30 days, $40.08 — per 30-day period), and 98980 (treatment management, first 20 minutes, $53.81 — per 30-day period). The per-cycle total is approximately $115.60. New for 2026: 98979 (treatment management, 10–19 minutes, ~$26) and 98985 (device supply, 2–15 days, ~$22) expand the code set for shorter observation windows. The billing provider must be the treating clinician — not the device company, not SolvingHealth. Revenue flows entirely to the practice.
The documentation requirement for RTM is 16 or more days of device-generated data within a 30-day billing period. The HealWithout SMS PROM engine — daily VAS score via Twilio — achieves a 98%+ open rate and ~45% reply rate (no app to install; responds directly to a text). Device session logs flow alongside the patient-reported data. The RTM attestation packet is auto-compiled from this data stream: the treating provider does not gather data. They review a structured summary, make any management notes, and sign. Total clinical time: 5–10 minutes per patient per billing period. The documentation burden that historically made RTM impractical for busy practices is eliminated.
Medicare's 90-day global surgery period bundles post-operative care — including RTM — into the operating surgeon's global surgical fee. During this window, the operating surgeon cannot bill RTM separately for Medicare patients. The solution is already built in: route RTM billing to the co-managing provider — PT, physiatrist, or PCP — who is outside the global period and eligible to bill independently. After day 90, or for non-Medicare payers, or for conditions not associated with the index surgery, the operating surgeon resumes full RTM eligibility. For the chronic-pain and wound-care patient populations, no global period applies — the prescribing clinician bills RTM from day one.
A practice with 30 active tPEMF patients on RTM protocol generates approximately $3,468 per month: 30 patients × $115.60. At 50 patients the monthly figure reaches $5,780. Over a calendar year at 30 patients, that is $41,600 in additional practice revenue that flows entirely to the billing clinician's NPI — not to the device company. A busy orthopedic surgeon who performs 10–15 joint replacements and rotator cuff repairs per month can reach 30 concurrent RTM patients within a single quarter. The documentation is auto-compiled; the clinical review takes 5–10 minutes per patient per month.
Three objections arise consistently. First, 'We don't have bandwidth for documentation.' The documentation generates automatically from device logs and SMS patient scores; the clinician reviews a structured summary and signs. The burden is minutes, not hours. Second, 'The 90-day global covers our surgical patients.' Correct for Medicare during the global window — but this routes to the co-managing PT or physiatrist, not to the surgeon. The surgeon's global payment is unaffected. Third, 'Patients won't use the monitoring system.' SMS response rates run above 90% open and 45% reply because it requires no app, no login, and no learning curve — patients text back from a number they already recognize.
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