TL;DR
Implementing RTM in 2026 is fundamentally different from previous years. CMS added three new CPT codes (98985, 98984, 98979) that eliminate the old “all-or-nothing” billing cliff, letting clinics get paid for patients who log as few as 2 days of data per month. Physical therapists, occupational therapists, and speech-language pathologists can bill these codes independently. With the right workflow, a practice managing 100 engaged patients can generate roughly $126,000 per year in RTM revenue alone.
What “Implementing RTM” Actually Means in 2026
Remote therapeutic monitoring is the use of digital tools to track a patient’s therapy adherence, musculoskeletal status, and treatment response between visits. Unlike remote physiologic monitoring (RPM), which captures things like heart rate and blood pressure, RTM focuses on non-physiological data: whether the patient did their exercises, how they rated their pain, whether they completed their home program.
That distinction matters because it’s what makes RTM billable by rehab professionals. PTs, OTs, and SLPs can bill RTM codes independently, without a physician co-signature. This opened an entirely new reimbursement channel when CMS first approved RTM codes in the 2022 Physician Fee Schedule. But adoption was slow, and the reason was structural.
Under the original rules, a patient had to transmit at least 16 days of data per month, and the treating clinician had to accumulate at least 20 minutes of treatment management time. Miss either threshold, and reimbursement dropped to zero. That all-or-nothing dynamic meant real clinical work, real patient engagement, and real staff time could result in no payment at all. Practitioners on Reddit and billing forums consistently pointed to this cliff as the top reason clinics either delayed RTM launches or abandoned early pilots.
The 2026 CMS Final Rule, released October 31, 2025, changed the math. Three new CPT codes now cover shorter monitoring durations (2 to 15 days of data) and lower time thresholds (10 to 19 minutes of management). The cliff is gone. CMS also confirmed that all RTM codes remain on the New Technology List through April 2030, signaling that this program is here to stay.
If you’re evaluating how to build RTM into your clinic operations, the RTM playbook for rehab practices covers the strategic foundation.
Complete 2026 RTM CPT Code Reference
Here is every RTM code available as of January 1, 2026, with national average reimbursement rates, billing frequency, and key rules.
Setup Code
| Code | Description | Reimbursement | Frequency | Key Rule |
|---|---|---|---|---|
| 98975 | Initial setup and patient education on RTM device/software | $21.71 (non-APM) / $21.82 (APM) | Once per episode of care | Must occur before any other RTM code is billed |
Device Supply Codes (MSK)
| Code | Description | Reimbursement | Frequency | Key Rule |
|---|---|---|---|---|
| 98985 (NEW) | MSK device supply, 2-15 days of data in a 30-day period | $51.00 | Per 30-day episode | Mutually exclusive with 98977 |
| 98977 | MSK device supply, 16-30 days of data | ~$51.00 | Per 30-day episode | Mutually exclusive with 98985 |
Device Supply Codes (Respiratory)
| Code | Description | Reimbursement | Frequency | Key Rule |
|---|---|---|---|---|
| 98984 (NEW) | Respiratory device supply, 2-15 days of data | $52.00 | Per 30-day episode | Mutually exclusive with 98976 |
| 98976 | Respiratory device supply, 16-30 days | ~$52.00 | Per 30-day episode | Mutually exclusive with 98984 |
Treatment Management Codes
| Code | Description | Reimbursement | Frequency | Key Rule |
|---|---|---|---|---|
| 98979 (NEW) | First 10-19 minutes of treatment management per month | $26.00 | Per calendar month | Mutually exclusive with 98980; no add-on code available |
| 98980 | First 20+ minutes of treatment management per month | $54.00 | Per calendar month | Mutually exclusive with 98979; can use 98981 add-on |
| 98981 | Each additional 20 minutes of treatment management | $41.42 (non-APM) | Per calendar month | Only billable as add-on to 98980 |
The 2026 conversion factor is $33.40 for non-APM and $33.57 for APM. Note that 98980 saw a significant rate increase from $48 in 2025 to $54 in 2026.
For a printable quick reference, the RTM cheat sheet for codes and rates breaks this down by billing scenario.
Key Terms Defined
Implementing RTM in 2026 means navigating a thicket of terminology that trips up even experienced billers. Here are the terms you’ll encounter, explained plainly.
All-or-Nothing Billing Cliff
The pre-2026 problem. Under original RTM rules, if a patient transmitted fewer than 16 days of data or the clinician logged fewer than 20 minutes of management time, the practice received zero reimbursement for that month. The new 98985 and 98979 codes create a lower tier that captures revenue from patients who engage partially. This single change is the biggest reason implementing RTM in 2026 is more viable than it was in 2024 or 2025.
De Minimis (10%) Standard
When a physical therapist assistant (PTA) or occupational therapy assistant (OTA) provides RTM services, the de minimis standard determines whether their involvement triggers additional modifier requirements. If the PTA/OTA performs more than 10% of the treatment management work, you must append the CQ modifier (for PTAs) or CO modifier (for OTAs). This standard applies to codes 98975, 98979, 98980, and 98981 but does not apply to the device supply codes (98985 and 98977).
Episode of Care vs. Calendar Month
This distinction causes real billing confusion. Device supply codes (98985, 98977, 98984, 98976) are billed per 30-day episode of care, which starts on the date the patient begins using the monitoring device. Treatment management codes (98979, 98980, 98981) are billed per calendar month. These periods often don’t align, especially for patients enrolled mid-month. A patient enrolled on March 15 has their device supply episode running March 15 through April 13, while their treatment management time resets on April 1.
FDA SaMD (Software as a Medical Device)
RTM requires the monitoring to occur through an FDA-cleared device or software application classified as Software as a Medical Device. This is where many clinics get burned. Using a generic EHR patient portal, a non-cleared app, or a basic survey tool does not satisfy this requirement. A common denial scenario: a clinic enrolls patients using a non-FDA-cleared app, submits 30 days of RTM claims, and every claim denies. Prevention is straightforward: request FDA 510(k) clearance documentation from your vendor in writing before enrolling your first patient.
GP / GO / GN Modifiers
Starting January 1, 2026, all RTM codes carry a “sometimes therapy” designation. This means you must append a discipline-specific modifier to every RTM claim. GP when services are furnished by a physical therapist. GO when furnished by an occupational therapist. GN when furnished by a speech-language pathologist. Missing these modifiers is one of the most common, and most preventable, denial triggers.
Interactive Communication
CMS requires at least one interactive communication with the patient during each calendar month to bill treatment management codes (98979, 98980, 98981). CMS defines interactive communication as “at a minimum, a real-time synchronous, two-way audio interaction.” That means a phone call or a video call. Texting and email do not count. This catches clinics off guard regularly. If your only patient contact is through a messaging platform, you cannot bill treatment management codes for that month.
KX Modifier and Therapy Cap Threshold
In 2026, the therapy cap threshold is $2,480. Once a patient’s combined therapy charges (including RTM) exceed this amount, you must append the KX modifier to indicate that services remain medically necessary. Documentation must support continued medical necessity for every service billed beyond this threshold.
Mutual Exclusion Rules
Several RTM rules prevent code stacking. RTM and RPM cannot be billed for the same patient in the same month. Within RTM, 98985 and 98977 are mutually exclusive (you bill one or the other based on data days). Similarly, 98979 and 98980 are mutually exclusive. If your cumulative treatment management time crosses from 19 minutes to 20 minutes during a month, you bill 98980 (not both). And 98981 can only be added onto 98980, never onto 98979.
New Technology List
CMS classifies all RTM codes as part of the New Technology List. This means the codes are protected from removal until at least April 2030, when CMS will review utilization data to determine whether changes are needed. For clinics investing in RTM infrastructure, this provides a meaningful runway.
Non-Physiological Data
What RTM actually monitors. Unlike RPM (blood pressure, heart rate, oxygen saturation), RTM tracks things like exercise adherence, pain levels, functional status, medication side effects, and therapeutic response. The patient typically self-reports this data through a software application, which is why the FDA SaMD requirement exists.
Patient Consent
Patient consent must be obtained before any RTM billing begins. The consent needs to document that the patient understands the service, any associated cost-sharing (copays, coinsurance), and their right to discontinue at any time. This is not a formality. Auditors look for it, and its absence can trigger recoupment. Capture consent before the first billable interaction, not after.
“Sometimes Therapy” Designation
A CMS classification indicating that a code can be billed by either a physician or a qualified therapist. All RTM codes received this designation effective January 1, 2026, per CMS Transmittal R13431CP. The practical impact: therapists must append the appropriate discipline modifier (GP, GO, or GN) to every RTM claim. Without it, the claim may process incorrectly or deny.
RTM vs. RPM: Quick Comparison
These two programs are often confused. They are distinct, and they are mutually exclusive per patient per month.
| Feature | RTM (Remote Therapeutic Monitoring) | RPM (Remote Patient Monitoring) |
|---|---|---|
| Data type | Non-physiological (adherence, pain, function) | Physiological (heart rate, BP, weight, SpO2) |
| Eligible billers | PTs, OTs, SLPs, physicians | Physicians and clinical staff under physician supervision |
| Device requirements | FDA-cleared SaMD permitted | Connected physiologic devices |
| Typical patients | MSK, respiratory, post-surgical rehab | Chronic conditions (hypertension, diabetes, CHF) |
| Co-billing | Cannot bill RTM + RPM for same patient in same month | Cannot bill RPM + RTM for same patient in same month |
| Code set | 8 codes (as of 2026) | Separate CPT code set (99453-99458) |
The critical takeaway for rehab practices: RPM is physician-territory. RTM is where PTs, OTs, and SLPs have independent billing authority.
Implementation Essentials: What Most Guides Skip
Knowing the codes is necessary. But practitioners on Reddit and in billing forums are clear: code knowledge is not where clinics struggle. The real barriers are workflow friction, patient buy-in, staff bandwidth, and documentation discipline. Here’s what actually determines whether implementing RTM in 2026 succeeds or stalls.
Patient Selection
Not every patient is a good RTM candidate. Prioritize post-surgical patients, chronic MSK conditions, early discharges, and patients with high fall risk or complex home programs. The patients most likely to generate consistent data, and therefore consistent revenue, are the ones already motivated to do their home exercises but lacking structure and accountability.
Consider the baseline: only about 30% of patients successfully complete home exercise programs. RTM doesn’t fix motivation problems by itself. It gives clinicians visibility into what’s happening between visits and creates accountability loops that improve patient engagement over time.
Consent and Enrollment
Get consent documented before the first billable interaction. The consent should cover what RTM is, what technology is involved, what the patient’s financial responsibility looks like (copays, coinsurance), and their right to opt out. Build this into your intake workflow so it’s not an afterthought.
For practical steps on building enrollment into your front-desk process, this guide on enrolling patients in remote monitoring walks through the sequence.
Workflow Design
This is where the gap between successful and unsuccessful RTM programs becomes stark. A clinIQ Healthcare analysis found that clinics using standalone RTM platforms report 35 to 40% eligible patient enrollment, while clinics with workflow-integrated RTM achieve 85 to 95% enrollment rates. The difference is friction. When RTM is a separate system requiring separate logins, separate documentation, and separate billing steps, staff skip it when they’re busy. When it’s built into the clinical workflow they already use, enrollment becomes automatic.
The clinics that succeed assign clear ownership for every step: who enrolls, who monitors data, who makes the monthly interactive communication call, who documents time, who submits claims. Ambiguity is the enemy.
Staff Training
Train by role, not in a single all-hands meeting. Clinicians need to understand patient selection criteria and how to make the interactive communication meaningful (not just a checkbox call). Front office staff need to handle consent, enrollment, and basic patient questions about the technology. Billing staff need to understand modifier requirements, mutual exclusion rules, and how to track cumulative management time across the month.
Documentation Standards
With audit frequency projected to increase to 12 to 15% in 2026, documentation must be tight. Every RTM encounter should include timestamps, cumulative time tracking for treatment management, data-day counts for device supply codes, and the FDA clearance status of the monitoring platform. The APTA’s updated RTM Practice Advisory, dated January 29, 2026, confirms that RTM should be implemented as an extension of existing clinical practice, not as a separate documentation workflow.
For documentation specifics, the RTM billing requirements checklist covers what auditors look for.
Common Denial Traps
Six scenarios that cause the most RTM claim denials:
- Non-FDA device. The monitoring platform lacks 510(k) clearance. All claims deny. Verify before enrolling.
- Missing modifiers. No GP, GO, or GN modifier on a therapist-billed claim. Automatic denial.
- RPM and RTM same month. A patient is enrolled in both programs during the same billing period. One set of claims will be rejected.
- No interactive communication. The clinic documented texting or portal messaging but never made a real-time phone or video call. Treatment management codes are ineligible.
- Wrong code pairing. Billing 98981 as an add-on to 98979 (it can only attach to 98980). Or billing both 98985 and 98977 for the same patient in the same period.
- Consent not documented. The audit finds no signed consent predating the first billed service. Potential recoupment.
A Note on Chiropractors
Medicare does not currently cover chiropractors for RTM billing. However, chiropractic clinics can pursue RTM reimbursement through commercial insurance, workers’ compensation, auto insurance, and cash-pay arrangements. If you’re a chiropractor evaluating RTM, verify payer-specific coverage before building your program around Medicare assumptions.
Revenue Context: Realistic Numbers
Revenue projections for RTM are everywhere online, and many are inflated. Here are grounded numbers based on 2026 national average rates.
Full-Engagement Monthly Stack (Per Patient)
| Code | Revenue |
|---|---|
| 98975 (setup, month 1 only) | $21.71 |
| 98977 (MSK device, 16+ days) | $51.00 |
| 98980 (treatment management, 20+ min) | $54.00 |
| Monthly total (after setup month) | $105.00 |
Low-Engagement Monthly Stack (Per Patient)
| Code | Revenue |
|---|---|
| 98975 (setup, month 1 only) | $21.71 |
| 98985 (MSK device, 2-15 days) | $51.00 |
| 98979 (treatment management, 10-19 min) | $26.00 |
| Monthly total (after setup month) | $77.00 |
Scaled Example
A practice managing 100 MSK patients on full-engagement RTM (98977 + 98980) generates approximately $10,500 per month, or $126,000 per year. Adding the new low-engagement tier for 50 additional patients who previously fell below the 16-day threshold adds roughly $3,850 per month. That’s revenue that simply did not exist before 2026.
These are Medicare rates. Some commercial payers reimburse at 120 to 140% of Medicare. Others don’t cover RTM at all yet. Before building revenue projections into your business plan, verify coverage with each payer individually. The improving patient experience to drive revenue guide covers how RTM fits into the broader clinic revenue picture.
A billing consultancy observation worth noting: most PT clinics that have launched RTM are either not billing it correctly or leaving specific codes on the table every month because the billing workflow was never properly configured. The revenue is real, but only if the operational infrastructure is sound.
Platform Cost Considerations
RTM revenue needs to be weighed against the cost of the monitoring platform, staff time, and workflow adjustments. Some platforms charge per-patient fees or take a revenue share. Others charge a flat monthly subscription. The economics vary widely depending on your patient volume and enrollment rates.
See AC Health’s pricing to compare flat-rate plans that include RTM automation without revenue sharing.
Mid-Month Enrollment: A Problem the 2026 Codes Solve
Before 2026, starting a patient on RTM on the 20th or 25th of the month created a billing nightmare. There was no realistic way to accumulate 16 days of data or 20 minutes of management time before month’s end. That meant the first partial month was almost always unbillable.
The new 98985 and 98979 codes fix this. A patient enrolled on the 25th who logs 5 days of data and 12 minutes of clinician time that month now qualifies for the lower-tier codes. The partial month is no longer wasted. This is a practical change that makes implementing RTM in 2026 viable for clinics that previously couldn’t justify the workflow overhead for patients with imperfect timing.
Standalone vs. Integrated Platforms: The Enrollment Gap
This deserves its own callout because the data is striking. Clinics using standalone RTM platforms (separate from their clinical workflow tools) report 35 to 40% enrollment of eligible patients. Clinics where RTM is integrated into the tools they already use daily achieve 85 to 95% enrollment.
The implication is clear: if your RTM system requires clinicians to log into a separate platform, manually export data, and complete additional documentation steps, you will lose most of your eligible patients to friction. The platforms that succeed converge home exercise prescription, patient communication, data monitoring, and billing reporting into a single workflow.
This is why understanding the RTM clinician workflow matters as much as understanding the codes themselves.
FAQ
Can I bill both the old and new codes for the same patient in the same month?
No. The device supply codes (98985 and 98977) are mutually exclusive. You bill one or the other based on how many days of data the patient transmitted during the 30-day episode. The same applies to treatment management: you bill either 98979 or 98980, not both. If your time crosses from 19 to 20 minutes during the month, you bill 98980.
Does texting count as interactive communication?
No. CMS defines interactive communication as real-time synchronous, two-way audio interaction. A phone call or video call qualifies. Text messages, emails, and asynchronous app messages do not. You must complete at least one qualifying interaction per calendar month to bill any treatment management code.
Can PTAs and OTAs provide RTM services?
Yes, but with restrictions. When a PTA or OTA performs more than 10% of the treatment management work (the de minimis standard), you must append the CQ modifier (PTA) or CO modifier (OTA). This standard applies to codes 98975, 98979, 98980, and 98981. It does not apply to device supply codes. The supervising therapist remains the billing provider.
What happens when cumulative time crosses from 10 minutes to 20 minutes mid-month?
Bill 98980 (the 20-minute code), not 98979. The codes are mutually exclusive. If you reach 20 minutes of treatment management time at any point during the month, 98980 becomes your base code. You can then add 98981 for each additional 20-minute increment. There is no add-on code for 98979.
Is RTM billable under commercial insurance?
It depends on the payer. The APTA’s January 2026 Practice Advisory confirms that RTM codes may be billable under commercial insurance plans. Some commercial payers reimburse at 120 to 140% of Medicare rates. Others have not yet adopted RTM coverage. Verify coverage with each payer before enrolling patients and building revenue projections.
What devices qualify for RTM?
The monitoring must occur through an FDA-cleared device or Software as a Medical Device (SaMD). Generic patient portals, standard survey tools, and non-cleared mobile apps do not qualify. Before signing with any RTM vendor, request their FDA 510(k) clearance documentation in writing.
How long will RTM codes be available?
CMS placed all RTM codes on the New Technology List, which means they remain in effect until at least April 2030. At that point, CMS will review utilization data and determine whether changes or updates are needed. This gives clinics a meaningful runway to invest in RTM infrastructure with reasonable confidence the program won’t disappear.
Why should my clinic implement RTM in 2026 specifically?
The structural barriers that held clinics back in previous years are gone. The all-or-nothing billing cliff has been eliminated. Reimbursement rates increased (98980 went from $48 to $54). The APTA has issued clear guidance. And the program is protected through 2030. Musculoskeletal conditions cost the healthcare system roughly $600 billion per year, and only 30% of patients complete their home exercise programs. RTM gives clinics both the clinical visibility and financial incentive to close that gap.
Getting Started
Implementing RTM in 2026 is no longer a speculative bet. The codes are established, the rates have improved, the lower thresholds unlock revenue that was previously unreachable, and the program has a protected runway through 2030.
The clinics that will capture the most value are those that treat RTM not as a bolt-on billing project but as an extension of clinical care, built into existing workflows with clear staff ownership, proper documentation, and a platform that minimizes friction.
Contact AC Health to see how RTM automation, custom video HEPs, and HIPAA-secure messaging work together in a single clinical workflow.
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