RTM Billing for Therapy Practices: The 2026 Code Set

Remote therapeutic monitoring got a structural fix for 2026. RTM is Medicare’s code set for monitoring nonphysiological patient data between visits: therapy adherence, exercise completion, symptom surveys, and functional status, collected through software apps rather than biosensors. For four years, RTM’s device supply and treatment management codes operated as an all-or-nothing threshold: 16 days of monitoring data or nothing, 20 minutes of management time or nothing. A patient who logged exercises in an app for 12 days, or a clinician who spent 14 minutes reviewing adherence data and coaching a patient by phone, generated real clinical work and no billable code. The CY 2026 Physician Fee Schedule final rule (CMS-1832-F) closes that gap with two new short-duration codes, 98985 for 2 to 15 days of musculoskeletal device data and 98979 for the first 10 minutes of monthly management, each paired against a mutually exclusive higher-duration code.

The code set now runs nine total codes across three device categories and one management category, plus the setup code. Every device supply pair and the two lower management tiers are mutually exclusive per patient per period, which means the billing question is no longer “did we clear the threshold” but “which tier applies this period.” Layered on top: the original RTM codes (98975, 98976, 98977, 98980, 98981) have carried a “sometimes therapy” designation since CY 2022, and CR 14250 (MLN Matters MM14250) added the three new codes (98979, 98984, 98985) to that list effective January 1, 2026. When a therapist furnishes any of these codes, the claim carries the same GP/GO/GN modifier and plan-of-care requirements as any other therapy service, and the same 10 percent de minimis standard governs when a PTA or OTA’s contribution requires the CQ or CO modifier.

This guide works from CMS-1832-F, CR 14250, and the CY 2022 final rule commentary that first defined RTM’s device standard. Current as of August 2026.

The 2026 RTM code set

Source for code descriptions and thresholds: CY 2026 PFS final rule (CMS-1832-F). Payment amounts are approximate national non-facility averages from the CMS Physician Fee Schedule Look-Up Tool, subject to geographic adjustment by locality. The 98978/98986 cognitive behavioral pair retains contractor pricing, meaning your Medicare Administrative Contractor sets the payable rate rather than the national PFS conversion factor.

The device supply codes run on 30-day periods; the treatment management codes run on calendar months. These are two separate clocks and practices should track them independently rather than assuming a device-data period and a management month line up.

What changed in 2026: the short-duration codes

Before 2026, a practice needed 16 or more days of device data in a rolling 30-day period to bill any device supply code, and 20 or more minutes of management time in a calendar month to bill any management code. Anything short of that produced billable clinical work with no corresponding claim, per the CY 2026 final rule.

CMS-1832-F adds a 2 to 15 day tier to each device category (98985 for MSK, 98984 for respiratory, 98986 for cognitive behavioral) and a 10 to 19 minute tier to treatment management (98979). The effect is that a patient who used a device for 9 days, or a clinician who spent 12 minutes on monthly review and coaching, now generates a billable claim at the corresponding lower rate instead of nothing. This removed what had functioned as a billing cliff since RTM’s introduction.

Who can bill RTM

PTs, OTs, and SLPs bill RTM independently. No physician or NPP co-signature is required for a therapist to furnish and bill the full code set, per CMS’s RTM policy carried forward into the CY 2026 final rule.

PTAs and OTAs can contribute to treatment management time under general supervision for 98979, 98980, and 98981, but not for the device supply codes. The de minimis (10 percent) standard, the same threshold governing CQ and CO modifier application on standard therapy codes, applies to 98975, 98979, 98980, and 98981: if a PTA or OTA furnishes more than 10 percent of the billed time, the claim requires the CQ or CO modifier and the corresponding 85 percent payment adjustment. The de minimis standard does not apply to the device supply codes (98977, 98985, 98976, 98984); those are billed on device-day counts, not clinician minutes, so there is no assistant-contribution calculation to run.

The “sometimes therapy” designation and modifier rules

Effective January 1, 2026, CMS designated all RTM codes “sometimes therapy” under CR 14250 / MLN Matters MM14250, the annual update to the list of codes that describe therapy services in some circumstances and non-therapy services in others. What that designation does depends on who furnishes the service:

• Therapist-furnished RTM (PT, OT, SLP) is always billed under a therapy plan of care and always requires the GP, GO, or GN modifier, exactly like any other outpatient therapy claim.
• Physician- or NPP-furnished RTM may be processed as a non-therapy service, without the therapy modifiers, with one carve-out: RTM billed in direct connection with the therapy device codes (98977 and 98985) does not get that exception.

Because therapist-furnished RTM now runs under a therapy plan of care, it also counts toward the same financial mechanisms that govern the rest of a patient’s therapy claims, including the KX modifier threshold that tracks cumulative therapy spending across a calendar year. Practices billing RTM alongside standard timed codes should fold it into the same threshold tracking rather than treating it as a separate ledger.

One useful contrast: RTM’s treatment management time is not subject to the 8-minute rule that governs unit counting on timed therapy codes. Management time accrues across the whole calendar month against a 10- or 20-minute floor, not in discrete 15-minute units per visit.

What counts as an RTM “device” (it is not a sensor)

RTM was built for nonphysiological data: therapy adherence, exercise completion, symptom surveys, and functional status reports. That is the defining difference from RPM, which collects physiological measurements like blood pressure or heart rate. RTM does not require a biosensor or wearable. The CPT descriptors cover “signs, symptoms, compliance, and functions of a therapeutic response,” and CMS has confirmed that patient-reported data qualifies, not just data captured by an objective measurement instrument.

The “device” in the device supply codes (98977, 98985) must meet the FDA’s definition of a medical device, but CMS’s standard is broader than most practices assume. It explicitly includes Software as a Medical Device (SaMD): a home exercise program app where a patient logs exercise completion, a digital therapeutic platform that collects pain and function surveys, or a patient-reported outcome tool that tracks therapy response over time. A patient recording that they completed their HEP in an app, or responding to structured prompts about exercise performance, generates exactly the kind of data transmission these codes describe. Consumer wellness trackers with no FDA classification and no clinical measurement claim do not qualify. This standard was established in CMS’s commentary in the CY 2022 PFS final rule, which created the RTM code set and defined the device eligibility criteria, and reaffirmed in the CY 2026 final rule.

RTM codes also remain on CMS’s New Technology status through April 2030, per the CY 2026 final rule, at which point CMS will review accumulated claims data to decide whether the code set or its pricing needs further revision.

The interactive communication requirement

98979, 98980, and 98981 all require at least one real-time interactive communication with the patient per calendar month. CMS’s language, carried in the CY 2026 final rule commentary, is that “live, interactive communication… contributes to the total time, but does not need to represent the entire cumulative reported time.” In practice, that means the communication is a gate, not the whole billable encounter: a single qualifying interaction opens the code, and other qualifying management activity in the same month adds to the time total.

Acceptable formats: phone, video, audio-only calls, and bidirectional digital communication where the exchange is live rather than store-and-forward. Not acceptable on its own: asynchronous texting or email, since neither is a real-time exchange. This is a narrower standard than Medicare’s telehealth rules, which govern an entirely separate billing pathway; RTM’s interactive communication requirement is about how the management time is earned, not about billing a visit as telehealth.

Consent and documentation

Patient consent has to be obtained and documented before RTM services begin, per CMS’s remote monitoring consent policy carried forward in the CY 2026 final rule. The record needs the date, the time, and who obtained the consent. Verbal consent is acceptable as long as it’s documented at the time it was given. A consent note that’s dated after monitoring has already started is an audit red flag, since it suggests the consent was documented retroactively rather than obtained up front.

Auditors reviewing RTM claims look for five elements in the record:

1. Consent, with date, time, and the name of the person who obtained it.
2. The specific device or app, named, with its FDA status noted.
3. Exact data day counts for the billed 30-day period, supporting whichever device supply tier was billed.
4. Treatment management time, logged with start and stop times or specific minute counts, not a round estimate.
5. Interactive communication records, each with a date, duration, and a note on what was discussed.

Round-number time entries (a suspicious number of exactly “20 minutes” or “10 minutes” logs) and copied or templated notes are both flagged by CMS contractors as documentation red flags rather than genuine time capture. This is the same standard Medicare’s general therapy documentation review applies to timed codes: the record has to support the specific minutes billed, not just state that the service occurred.

What RTM cannot be billed with

The mutual exclusivity rules, per the CPT code descriptors and the CY 2026 final rule commentary, run at three levels:

• Device supply, per 30-day period, per category. A patient gets either 98985 (2–15 days) or 98977 (16–30 days) for MSK monitoring in a given 30-day period, never both. The same either/or applies to the respiratory pair (98984/98976) and the cognitive behavioral pair (98986/98978).
• Treatment management, per calendar month. A patient gets either 98979 (10–19 minutes) or 98980 (20+ minutes) in a given month, never both. 98981 stacks only on top of 98980 for additional 20-minute increments; it cannot follow 98979, so there’s no path to bill 98979 plus 98981 in the same month.
• RTM and RPM. Remote therapeutic monitoring and remote patient monitoring cannot both be billed for the same patient in the same calendar month.

There’s also a single-biller rule that sits underneath all of the above: only one billing clinician can bill RTM for a given patient in a given 30-day period. A practice running RTM across multiple disciplines for the same patient needs to coordinate who owns the billing for that period rather than assuming each discipline can bill independently.

RTM billing lives at the intersection of two things a therapy practice has to get right independently: the monitoring data itself, and the plan of care it’s attached to. Rehab Prescribed builds CPG-based home exercise programs and tracks client response and compliance, the exercise adherence data that feeds MSK RTM billing and generates the day counts that support 98977 and 98985. PrismEHR documents the therapy plan of care RTM now requires under the “sometimes therapy” designation, applies the GP/GO/GN and CQ/CO modifiers automatically where the de minimis standard is met, and logs treatment management time against the correct calendar-month clock. See how the two fit together for physical therapy practices.