Mistakes Practices Make When Starting an RTM Program
RTM billing codes changed on January 1, 2026, and practices had been preparing for it since last year. Many launched their programs right as the new codes took effect, with a lot of enthusiasm behind them. A few months in, we started hearing from practices that had reached out to us wanting to understand why their RTM programs were not performing as well as their peers who had launched their RTM programs with Actuvi. When we dug into it, the issue was never RTM itself. It was how the program was set up. These are the most common reasons that came up.
1. Starting without a clear patient enrollment process
RTM only generates revenue when patients are actively enrolled and submitting data. The mistake many practices make is launching the platform without defining who enrolls patients, when enrollment happens in the visit workflow, and what the patient is told at the point of enrollment.
When enrollment is left undefined, it becomes nobody's job. Patients leave appointments without being enrolled, and the RTM program sits unused. Before going live, a designated care team member needs to own the enrollment step, and it needs to be built into the visit workflow at a specific touchpoint.
2. Choosing a platform that doesn't fit into your existing care pathways
RTM works best when it fits into how a practice already operates, not when the practice has to change how it works to accommodate a platform. A common mistake is selecting a platform that offers generic, one-size-fits-all assessment templates that have no relationship to what a practice is actually tracking for its patients.
When a platform's assessments don't map to what a practice already does, the data it collects has limited clinical use. Providers stop reviewing it, and the program loses momentum. The right platform builds assessments and clinical thresholds around how your practice already manages patients, not the other way around.
Actuvi builds custom assessments and clinical thresholds that fit into your existing care pathways. Whether a practice runs a pain clinic, a mental health clinic, a rural health clinic, or any other specialty, Actuvi designs the RTM program around the way the practice already works.
3. Treating RTM like RPM
RTM and RPM are separate programs with different billing codes, different patient populations, and different types of data. RPM tracks physiological data, such as blood pressure or blood glucose, typically through connected devices. RTM tracks non-physiological, patient-reported data, such as pain levels, functional status, anxiety levels, treatment adherence, and more.
Practices that conflate the two end up either billing incorrectly, enrolling the wrong patients, or choosing a platform built for one program and trying to force it into the other. RTM does not require physiological device readings. It is built on what patients report, which is a fundamentally different data type with its own CPT codes and billing thresholds.
Any practice evaluating an RTM platform needs to confirm that the platform is designed specifically for RTM, and that its billing reflects RTM CPT codes, not RPM codes.
4. Assuming patients will stay engaged without support
Keeping patients consistently submitting data is the single biggest challenge in running an RTM program. A practice can have the right platform, the right workflows, and the right billing setup, and still underperform if patients stop submitting data after the first week or two. Practices make the mistake of assuming that once a patient downloads the app, they will continue using it without any prompting.
Without a compliance layer built into the platform, engagement drops quickly. The platform a practice selects needs to have automated reminders and notifications built in, and a mechanism to re-engage patients who go quiet.
Actuvi's patient app includes automatic notifications and reminders to keep patients submitting data consistently. For patients with low compliance rates, Actuvi's AI agents follow up through text messaging, bringing compliance rates up significantly without any manual effort from the care team. For practices with patients who cannot use a smartphone independently, Actuvi's Guardian Access feature allows a designated guardian to submit data on the patient's behalf, so enrollment is not limited by a patient's age or ability to use a device.
5. Ignoring data security and compliance requirements
RTM involves collecting protected health information (PHI) through a patient-facing mobile application. Any platform handling that data needs to meet specific regulatory requirements. Practices that skip this evaluation during vendor selection expose themselves to compliance risk.
The platform must be HIPAA compliant. For practices with international patient populations or operating in markets outside the US, GDPR compliance is also relevant. The patient-facing app should meet FDA regulations for software as a medical device (SaMD). Patient data should be encrypted and stored within the appropriate jurisdiction.
Actuvi is both HIPAA and GDPR compliant. Patient data is encrypted and stored on servers within the client's country. Actuvi's mobile app meets FDA regulations for software as a medical device (SaMD) for remote therapeutic monitoring, and the platform is listed with the FDA.
6. Selecting a platform that puts the billing work on your staff
RTM billing has specific time thresholds tied to CPT codes. Billing requires documentation of how many minutes were spent reviewing patient-reported data within a given period. Practices that choose platforms without automated time tracking end up relying on staff to manually log that time, which creates administrative burden and increases the risk of incomplete documentation.
The right platform tracks time automatically and generates ready-to-submit billing reports without requiring staff to do it manually.
Actuvi automatically tracks all the time the care team spends monitoring patient-reported data and generates billing reports that are ready to submit.
7. Failing to validate patient insurance upfront
The program will still face financial roadblocks if patient insurance is not validated prior to enrollment. A common oversight is assuming all payers cover RTM codes or failing to check a patient's specific eligibility and benefits.
When practices do not validate patient insurance profiles to confirm exactly who they are and what their specific plan covers, they face unexpected claim denials downstream. Ensuring your front office or billing team confirms active coverage at the start is essential.
8. Building the program yourself after buying the platform
This is perhaps the most common and avoidable mistake. A practice purchases access to an RTM platform, and then the vendor hands them the keys and walks away. The practice is left to build the assessments, set up the thresholds, train the staff, and manage the enrollment process on its own. Most practices are not equipped to do this, and most don't have the time.
A platform purchase is not the same as a program launch. The platform a practice selects should handle the setup. That means building the assessments, configuring the thresholds, and supporting the practice through go-live so that the program is running from day one.
Actuvi builds and launches RTM programs for practices. Actuvi designs the workflows, creates the custom assessments for your specialty, and configures everything to fit into your care pathways before your first patient is enrolled.
Launch Your RTM Program with Actuvi
Now that you know what to watch out for, most of these mistakes are entirely avoidable. The practices that run successful RTM programs are not doing anything extraordinary. They just have the right setup from day one.
Launching an RTM program that runs well from the start comes down to choosing a platform that does the work, not one that requires your practice to figure everything out on its own. Actuvi builds and launches RTM programs for practices of all sizes across all specialties. Book a call with our RTM expert to get started.
