The CPT update isn’t usually where strategy teams start. But this year, it probably should be.
The 2025 set introduces 270 new codes, cuts 112, and revises 38 — and taken together, they mark a shift in how digital health services are being evaluated.
Remote care is getting more narrowly defined. Low-touch check-ins that used to be reimbursable are now harder to justify. And the new codes reflect a pattern: more clinical accountability, more documentation rigor, and a clearer line between what’s billable and what’s just supportive.
For digital health companies, this isn’t just a coding update. It’s a signal to recheck assumptions — about what payers will fund, what buyers will question, and where your solution fits in a more scrutinized reimbursement landscape.
This guide breaks down what CPT codes are billable for digital health in 2025 — and what it means for your GTM, pricing model, and buyer story.
Remote Patient Monitoring (RPM)
CPT codes: 99453, 99454, 99457, 99458, 99091
If your solution collects physiologic data from an FDA-defined device (think: blood pressure, weight, glucose), and pairs it with some level of ongoing review or patient contact, it likely fits into RPM.
→ 99453 covers patient onboarding and setup
→ 99454 is for the device supply and data sync — billable monthly
→ 99457/99458 are for the clinical management minutes — 20+ minutes required
→ 99091 is still valid for physician-led review, though used less often
What’s important in 2025:
The thresholds didn’t change. You still need:
- At least 16 days of data in a 30-day window to bill 99454 (but will change by January 2026)
- At least 20 minutes of interaction with real-time patient contact (phone or video) for 99457
But policy changes hit community clinics: FQHCs and RHCs can no longer use the bundled G0511 to cover RPM. They now must bill using the specific RPM codes — which means your solution needs to support code-level documentation and unbundled workflows if you’re selling into those markets.
If your RPM capability includes device provisioning, onboarding, and patient engagement — and can document the required thresholds — each of those touchpoints can drive CPT-based revenue.
Remote Therapeutic Monitoring (RTM)
CPT codes: 98975, 98976, 98977, 98978, 98980, 98981
If RPM is about vital signs, RTM is about symptoms, adherence, and therapy engagement. Think: pain tracking, inhaler use, sleep, medication adherence, or digital rehab.
RTM was built to track non-physiologic data, often through self-reporting or connected devices, and it’s increasingly where digital health vendors — especially those working in behavioral, musculoskeletal, or respiratory care — are landing reimbursement traction.
What’s billable:
→ 98975 — initial setup and patient education (once per episode of care)
→ 98976 — monthly supply of a respiratory monitoring device
→ 98977 — monthly supply of a musculoskeletal monitoring device
→ 98978 — supply code for cognitive/behavioral digital therapeutics
→ 98980/98981 — monthly clinical management (first 20 min + each add’l 20)
Like RPM, RTM requires:
- 16 days of data during the month for device supply codes
- At least one interactive communication (e.g., a call or live message) with the patient per month
- Clinical review and engagement — no autopilot workflows
What changed in 2025:
- 98978 added to cover digital therapeutic monitoring — especially for behavioral health or cognitive therapy tools. This is a clear signal that CMS and AMA are validating software-led therapeutic interventions.
- Descriptors updated across the RTM family — now include digital interventions, not just hardware.
Who can bill:
Unlike RPM, which is tied to Evaluation and Management services, RTM can be billed by non-physician clinicians — physical therapists, occupational therapists, respiratory therapists, and others.
That distinction matters in your GTM approach. If your solution is used by therapy providers or rehab clinics, RTM codes give them a way to turn those workflows into revenue.
Where we’re seeing traction:
- Post-surgical rehab programs using app-based exercise trackers
- Asthma/COPD programs tracking inhaler adherence
- Pain management workflows tied to symptom check-ins and motion sensors
- Behavioral health programs bundling therapy modules with patient reporting
RTM is still early for many vendors, but the 2025 changes made it easier to qualify — and more types of solutions now fit inside it.
If your solution includes therapeutic monitoring, patient-reported data, and at least one human touchpoint, this is your billing category.
Chronic Care Management (CCM)
CPT codes: 99437, 99439, 99490, 99491, 99487, 99489
For patients with two or more chronic conditions expected to last at least 12 months or until the patient’s death, CCM is still one of the most accessible reimbursement paths in the system.
→ 99490 covers 20 minutes of non-face-to-face care coordination
→ 99439 is for each additional 20 minutes (must be billed with 99490)
→ 99491/99437 are used when the physician (rather than staff) delivers the service
→ 99487 – 60 minutes of complex CCM (moderate/high complexity)
→ 99489 – each additional 30 minutes of complex CCM
These codes are billable monthly and have real traction in primary care, geriatrics, and population health settings.
In 2025:
You can still bill RPM and CCM in the same month, but the time must be distinct, and services must be clearly documented
Why it matters for PMs and GTM leads: If your solution supports care planning, patient outreach, and team-based care, it’s likely CCM-compatible.
Principal Care Management (PCM)
CPT codes: 99424, 99425, 99426 and 99427
If your solution supports care management for patients with a single high-risk or complex chronic condition, it may fit under PCM.
→ 99424 covers 30 minutes of physician or other qualified healthcare professional time per month
→ 99425 is for each additional 30 minutes of physician time
→ 99426 is for 30 minutes of clinical staff time directed by a physician or other qualified professional
→ 99427 is for each additional 30 minutes of staff time
What’s important in 2025:
PCM codes can only be billed for patients not currently receiving CCM services — it’s one or the other. This makes PCM a good fit for earlier-stage chronic disease programs or specialty clinics focused on a single condition like heart failure, diabetes, or COPD.
If your platform supports condition-specific care planning, task tracking, and regular touchpoints (phone, portal, etc.), PCM can turn that engagement into revenue — especially for specialists managing patients who don’t qualify for broader CCM.
It’s also a good strategic foothold if you’re working with partners who want to prove value in a targeted population before scaling to more complex care models.
Digital E/M and Asynchronous Evaluation
CPT codes: 99421–99423 (online digital E/M), 99451, 99452, 99446, 99447, 99448, 99449 (interprofessional consult), 98970–98972 (non-E/M digital evals)
These codes cover asynchronous reviews, patient portal messages, and non-live consults. The billing logic is based on total cumulative time spent responding to or evaluating a patient’s request over a seven-day period.
Good fit for:
- Solutions that facilitate portal-based care
- Clinical AI tools that prep a provider with patient-submitted data
- Asynchronous specialist consults or store-and-forward models
Limitations:
- Must be initiated by the patient
- Time thresholds must be met (5–10, 11–20, 21+ minutes tiers for E/M)
If your solution allows providers to evaluate or respond to patients outside of live encounters — and that time is trackable — this can be a monetizable touchpoint.
Telehealth and Brief Virtual Visits
CPT codes: 99202-99205, 99211-99215
While some telehealth flexibilities from the COVID-19 public health emergency are being phased out, many brief virtual visits — including audio-only encounters for primary care — remain reimbursable through September 30, 2025.
- Still covered by Medicare when the provider has audio-video capability and the patient is unable or unwilling to use video (modifier 93 required for audio-only).
- Still supported by private payers, though payment parity and coverage rules vary by state and insurer.
Billing logic:
- Standard E/M codes (99212, etc.) can be used if the visit meets full documentation requirements
Even lightweight digital touchpoints — when structured correctly — can be monetized. If your solution facilitates quick triage, follow-ups, or non-urgent care delivery, you don’t have to hit the 20-minute RTM/RPM threshold to make it count.
CPT codes 99441–99443 (audio-only E/M) were phased out in January 2025, and providers must now bill 99202–99215 with modifier 93 for audio-only services.
Place of service codes must reflect where the patient is located:
- POS 10 = patient’s home
- POS 02 = other telehealth location
What Digital Health Features Aren’t Billable Under CPT Codes in 2025
There’s a long tail of features in digital health that feel clinically meaningful — but aren’t reimbursable under current CPT logic. Some of these gaps are being addressed in future code updates, but for 2025, here’s where monetization falls flat.
1. No Live Interaction
To bill 99457, 99458, 98980, or 98981, the provider must have interactive communication with the patient.
That means a phone or video conversation — not just messaging.
Even if clinical staff reviews data and updates a care plan, without that live contact, the time doesn’t count.
For vendors focused on automation or low-touch engagement: unless you structure some form of live outreach, you’re building around a non-billable model.
2. Double Billing (or Conflicting Codes)
- You can bill RPM + CCM in the same month — but not for the same minutes of care.
- You can’t have two practices billing RPM or RTM for the same patient in the same calendar month. This comes up often in distributed care models — especially when a third-party vendor or care team is involved.
If multiple orgs are engaging the same patient, only one can claim the codes. You’ll need to be clear about ownership and documentation.
3. Algorithm-Only Monitoring
If your platform generates alerts based on patient data but no human reviews or acts on them, it’s not billable.
CPT logic requires clinical involvement — software alone doesn’t count, no matter how “intelligent” it is.
For digital health companies leaning into AI: you’ll need to pair the intelligence with a care team layer if you want to generate CPT revenue.
How Digital Health Companies Should Use CPT Codes to Drive Revenue in 2025
It’s easy to look at CPT codes as someone else’s problem — a compliance concern or a rev cycle footnote. But for digital health companies building and selling into U.S. care delivery, reimbursement logic is workflow logic.
If your solution can’t translate into billable actions, it won’t get prioritized, adopted, or renewed. Period.
So here’s how to make CPT part of the build-measure-learn cycle — not just the billing appendix.
1. Map Product Features to Code Requirements
Every billable code has gating criteria: time, data frequency, type of interaction, who reviews it, how it’s captured.
Example: Want to enable RPM? Then:
- Your device needs to transmit 16+ days of data per month
- There must be a mechanism to log 20 minutes of clinician interaction
- The team must have a way to initiate a two-way communication (not just send a push notification)
If even one piece is missing, the provider gets nothing. That’s a product gap with a revenue consequence.
2. Design for Modular Documentation
Reimbursement doesn’t just depend on what the solution does — it depends on what can be documented, attributed, and billed.
Especially in settings like community clinics or group practices, your solution needs to support:
- Code-level documentation
- Distinct service attribution (e.g., for RPM vs. CCM)
- Multi-user workflows where nurses, therapists, or physicians all have separate roles
If providers can’t track which patient interaction maps to which code, they’re not going to fight to prove value. The solution just gets deprioritized.
3. Enable Sales With Reimbursement Stories
Buyers don’t just want features. They want to know if this solution helps them get paid.
- Build GTM messaging that connects your product directly to the CPT code it activates.
- Arm reps and customer success teams with revenue scenarios:
- “When your nurse reviews RPM data and follows up by phone, that interaction is billable under 99457.”
- “With just 16 days of device data, this kit qualifies for monthly reimbursement.”
- “You’re already doing this work — this solution just makes it billable.”
When buyers can see reimbursement clarity in your demo, everything else follows.
4. Stay Ahead of the Curve
If your program consistently falls just short — 14 days of data instead of 16, or 17 minutes instead of 20 — that’s not just a clinical issue. That’s a monetization failure.
2026 codes may fill those gaps. But if you’re building now, you need to design for what’s reimbursable today while laying groundwork for what’s coming.
Monitor descriptor changes, threshold relaxations, and pilot programs. They signal where CPT logic is headed — and where you can move early.
Reimbursement Is Your GTM Edge
CPT codes aren’t just for the billing team — they’re a map of what matters to your buyers. When your product aligns with reimbursable actions, it becomes a necessity.
You don’t need to be a clinician to build something valuable, you just need to understand how value gets captured — and how to design for it.
If you’re refining your product roadmap, building your revenue story, or just getting clarity on where you fit — we help teams turn reimbursement insight into GTM traction.
