Can LCSWs, LMFTs, and LPCs Bill RTM Codes? Provider Eligibility by License Type

The most common question we hear from mental health clinicians about Remote Therapeutic Monitoring is not about the codes, the reimbursement rates, or the documentation. It is: "Am I even allowed to bill this?"

The short answer is that CMS defines RTM-eligible providers as "physicians and other qualified healthcare professionals." That language is intentionally broad, and it includes many mental health license types. But the details vary by license, by state, and by payer. Here is what we know as of 2026, broken down by license type.

What CMS Says About RTM Provider Eligibility

CMS does not publish a specific list of license types eligible for RTM billing. Instead, they use the term "physicians and other qualified healthcare professionals" (QHPs), which is a defined term in the CPT code system. A QHP is a healthcare professional who is qualified by education, training, licensure, and facility privileging to perform a specific service.

For RTM specifically, the 2026 Physician Fee Schedule Final Rule states that RTM services can be billed by physicians, nurse practitioners, physician assistants, clinical psychologists, licensed clinical social workers, physical therapists, occupational therapists, and speech-language pathologists.

The critical qualifier: the provider must be operating within their state scope-of-practice laws. CMS defers to individual states on scope-of-practice questions. A license type that is eligible under federal CMS rules may face restrictions in certain states.

Eligibility by License Type

Psychiatrists (MD/DO) Eligible. No restrictions. Psychiatrists are physicians and can bill all RTM codes without limitation.

Clinical Psychologists (PhD, PsyD) Eligible. Clinical psychologists are explicitly listed by CMS as qualified healthcare professionals for RTM billing. They can bill all RTM codes when operating within their scope of practice.

Licensed Clinical Social Workers (LCSW) Eligible. LCSWs are explicitly recognized by CMS as qualified healthcare professionals. They are Medicare-eligible providers and can bill RTM codes. This is the most common license type among therapists in private practice, and eligibility is well established.

Licensed Professional Counselors (LPC) / Licensed Mental Health Counselors (LMHC) Eligible with a recent caveat. LPCs and LMHCs became Medicare-eligible providers as of January 1, 2024, following the passage of provisions in the Bipartisan Budget Act. Prior to 2024, they could not bill Medicare directly. Now that they are Medicare-eligible, they can bill RTM codes. However, because this is relatively new, some LPCs report confusion from payers who have not fully updated their systems. If you are an LPC billing RTM for the first time, confirm with your specific Medicare Administrative Contractor (MAC) and any commercial payers.

Licensed Marriage and Family Therapists (LMFT) Eligible with the same caveat as LPCs. LMFTs also became Medicare-eligible providers as of January 1, 2024. They can now bill RTM codes under Medicare. The same practical considerations apply: confirm with your MAC and commercial payers, as some systems may not have fully updated.

Licensed Professional Clinical Counselors (LPCC) Same as LPC. The specific title varies by state but the eligibility pathway is the same.

Psychiatric Nurse Practitioners (PMHNP) Eligible. Nurse practitioners are explicitly listed by CMS as qualified healthcare professionals for RTM billing. PMHNPs can bill all RTM codes.

Physician Assistants (PA) Eligible. PAs are explicitly listed by CMS for RTM billing.

Pre-licensed clinicians (associates, trainees, interns) Not eligible. Pre-licensed clinicians cannot bill Medicare or RTM codes independently. If they are providing RTM services, the billing must go through a supervising qualified healthcare professional.

The State Scope-of-Practice Variable

Federal CMS eligibility is necessary but not sufficient. Your state scope-of-practice laws must also permit the activity being billed.

In most states, monitoring client therapeutic response between sessions falls clearly within the scope of practice for all the license types listed above. Therapists have always been allowed to check in on clients between appointments, review homework, and adjust treatment plans based on new information. RTM is the billing mechanism for formalizing and compensating that activity.

However, some states have specific restrictions on what constitutes "monitoring" versus "treatment" versus "assessment," and how those distinctions affect billing authority. We are not aware of any state that has specifically prohibited mental health clinicians from billing RTM codes, but given that this is a new billing category, there may be states where guidance has not yet been issued.

The practical step: check with your state licensing board and your state's mental health professional association. Many state associations have issued guidance on RTM billing for their members.

Medicare vs. Commercial Insurance

RTM codes are Medicare codes. CMS sets the rates and rules for Medicare reimbursement. All the eligibility information above applies directly to Medicare billing.

Commercial insurance is a different landscape. Some commercial payers reimburse RTM codes at Medicare rates or higher. Others have not yet adopted RTM billing. Adoption is growing but inconsistent as of 2026.

If your practice is primarily commercial insurance, do the following before building revenue projections around RTM:

Contact your top 3-5 payers and ask specifically whether they reimburse CPT codes 98975, 98978, 98980, and 98981. Ask what their requirements are for provider eligibility, documentation, and device specifications.

Check whether your payer contracts include a provision for "new CPT codes" or "codes adopted by CMS." Some contracts automatically cover new CMS codes. Others require explicit addition.

Consider starting with your Medicare clients as a pilot. Medicare eligibility and reimbursement are clear. Use that cohort to build your RTM workflow and documentation practices before expanding to commercial payers.

Supervision Requirements

RTM services fall under "general supervision" at the federal level. This means the supervising provider does not need to be physically present when the monitoring data is being collected or reviewed. The provider must be available for consultation and must exercise clinical oversight of the program.

For mental health clinicians in private practice, this is straightforward. You are the supervisor. You set up the monitoring, your clients transmit data, and you review it on your own schedule.

For group practices where multiple clinicians share clients or where pre-licensed associates provide support: RTM codes must be billed under the supervising qualified healthcare professional. The associate can assist with data review and client communication, but the billing provider must be involved in clinical decision-making.

When RTM codes are furnished by therapy assistants (PTAs or OTAs in physical therapy contexts), CQ or CO modifiers are required. This is less relevant for mental health clinicians but worth noting for interdisciplinary practices.

The "Sometimes Therapy" Designation

As of 2026, CMS has designated several RTM codes as "sometimes therapy" services. This means the codes can be billed either as therapy services or as non-therapy medical services, depending on the context.

When a mental health clinician bills RTM codes, the services are typically billed as non-therapy medical services unless they are specifically provided under a therapy plan of care. This distinction matters for billing modifiers: if RTM is provided under a therapy plan of care, GP, GO, or GN modifiers are required depending on the discipline.

For most mental health therapists in private practice billing RTM as part of general clinical monitoring (not under a rehabilitation therapy plan of care), this designation does not change the billing process. But if you are in an interdisciplinary practice or billing through a facility, consult with your billing team on the correct modifier usage.

Getting Started

If you have confirmed that your license type is eligible and your state permits RTM billing, the next steps are:

Read our complete RTM billing guide for the full code breakdown, rates, and billing process.

Understand CPT 98978, the code most relevant to mental health monitoring.

Review the documentation requirements before you start so your claims are clean from day one.

Run the numbers with our revenue calculator to understand the financial impact for your specific practice.