TL;DR
RTM billing requirements are the rules CMS sets for providers to get reimbursed for remote therapeutic monitoring services. For 2026, CMS expanded the program with new CPT codes that lower minimum thresholds from 16 days and 20 minutes down to 2 days and 10 minutes. PTs, OTs, and SLPs can bill RTM independently without physician co-signatures. Meeting the requirements comes down to five things: using an FDA-defined device, hitting data day thresholds, logging treatment management time, completing at least one real-time interactive communication per month, and documenting patient consent before services begin.
What Are RTM Billing Requirements?
RTM billing requirements are the specific conditions a provider must satisfy before submitting a claim for remote therapeutic monitoring under Medicare (and, increasingly, commercial payers). These conditions cover everything from which CPT codes to use and how many days of data to collect, to what kind of patient communication counts and what documentation an auditor expects to see in the chart.
Remote therapeutic monitoring differs from other remote care programs because it captures non-physiologic data: things like musculoskeletal function, respiratory status, treatment adherence, and patient-reported outcomes. Unlike remote physiologic monitoring (RPM), RTM data can be self-reported by the patient through a qualifying device or app.
The CY2026 Physician Fee Schedule Final Rule brought the biggest expansion since RTM launched, adding new codes and lower thresholds that make the program accessible to far more practices. If you’re a physical therapist, occupational therapist, or speech-language pathologist, RTM is the code set you can bill independently. No physician co-signature required. No transfer of billing rights.
See AC Health’s RTM-capable plans and pricing →
RTM vs. RPM: The Difference That Causes the Most Denials
Confusing RTM with RPM remains one of the most common billing errors, according to multiple billing consultants and payer audit reports. Here’s the quick breakdown:
| RTM | RPM | |
|---|---|---|
| Data type | Non-physiologic (MSK function, adherence, treatment response) | Physiologic (blood pressure, weight, pulse ox) |
| Patient self-report | Allowed | Not allowed |
| Who can bill | PTs, OTs, SLPs, physicians, NPs, PAs | Physicians and certain non-physician practitioners (not PTs/OTs/SLPs independently) |
| Typical use | Post-surgical rehab, chronic MSK conditions, HEP adherence tracking | Chronic disease management (hypertension, diabetes, COPD) |
The critical mutual exclusion rule: RPM and RTM cannot be billed together for the same patient in the same calendar month. Only one clinician can bill RTM codes in a 30-day period per patient. However, RTM can be billed concurrently with CCM, PCM, and BHI when each program’s requirements are independently met.
If your clinic treats patients who also see a physician managing a chronic physiologic condition, coordinate. Billing both RTM and RPM for the same patient in the same month will trigger a denial.
2026 RTM CPT Code Quick Reference
The 2026 expansion added three new codes (marked below), lowering the barrier for practices that previously couldn’t meet the 16-day and 20-minute minimums. RTM now has eight total CPT codes, though the table below focuses on the musculoskeletal codes most relevant to rehab providers.
| Code | Description | Threshold | Frequency | 2026 Approx. Payment |
|---|---|---|---|---|
| 98975 | Initial setup and patient education | Minimum 2 days of monitoring must occur | Once per episode of care | ~$21.71 |
| 98985 (NEW) | MSK device supply, 2-15 days | 2-15 days in a 30-day period | Once per 30-day period | ~$51.00 |
| 98977 | MSK device supply, 16-30 days | 16-30 days in a 30-day period | Once per 30-day period | ~$40.08 |
| 98979 (NEW) | Treatment management, first 10 min | 10-19 minutes of management time | Once per calendar month | ~$22-25 |
| 98980 | Treatment management, first 20 min | Minimum 20 minutes | Once per calendar month | ~$54.00 |
| 98981 | Treatment management, each additional 20 min | Additional 20-minute increment | Add-on to 98980 only | ~$41.00 |
Respiratory (98976/98986) and cognitive behavioral (98978/98987) device supply codes also exist but fall outside the typical rehab therapy scope.
Mutual Exclusion Rules for Codes
These rules trip up even experienced billers:
- Device supply codes are mutually exclusive. Bill either 98985 (2-15 days) or 98977 (16-30 days) for the same patient in the same 30-day period. Never both.
- Treatment management base codes are mutually exclusive. Bill either 98979 (first 10 min) or 98980 (first 20 min) for the same patient in the same calendar month. Never both.
- 98981 stacks only on 98980. The additional 20-minute code cannot be added on top of 98979. If your management time lands between 10 and 19 minutes, 98979 is your ceiling for that month.
Understanding which apps support 98977 and 98981 matters here, because your platform needs to track these thresholds automatically to avoid billing errors.
Core RTM Billing Requirements Checklist
Every RTM claim rests on the same foundation. Miss one element and the claim gets denied, or worse, survives initial payment but fails a post-payment audit. Here’s what must be in place:
1. Medical Necessity and Therapy Plan of Care
RTM services must be furnished under a therapy plan of care. The monitoring has to connect to a documented clinical goal. You’re not monitoring for monitoring’s sake.
2. FDA-Defined Medical Device (Including SaMD)
CMS requires that the monitoring device meet the FDA’s definition of a medical device. Software applications can qualify as Software as a Medical Device (SaMD), but consumer-grade wearables and generic wellness trackers do not. One compliance advisor at Orva Health put it bluntly: “Consumer-grade wearables are not reliable enough to inform clinical decisions, and payers know it. If you are using non-compliant devices, billing audits can force you to repay what you collected.”
This is the requirement most clinics overlook. Name the device or app in your chart notes. Document why it qualifies as a medical device. Confirm HIPAA controls and a Business Associate Agreement with your vendor.
3. Data Day Thresholds
The 2026 expansion created two tiers:
- Low-engagement tier: 2-15 days of data collection in a 30-day period (bill 98985)
- Full-engagement tier: 16-30 days (bill 98977)
The setup code (98975) requires at least 2 days of monitoring to have occurred. Previously, the 16-day minimum was an all-or-nothing cliff. A patient who engaged for 14 days generated zero RTM revenue. The new 2-day floor changes that calculus entirely.
4. Treatment Management Time Thresholds
Again, two tiers since 2026:
- 10-19 minutes of treatment management services in a calendar month (bill 98979)
- 20+ minutes (bill 98980, with 98981 for each additional 20-minute block)
Time must be documented with specificity. Round numbers raise red flags. “20 minutes exactly” every month for every patient is a pattern auditors will question.
5. Interactive Communication
This is non-negotiable. You can only bill 98979, 98980, or 98981 if at least one interactive communication with the patient occurred during the calendar month. CMS defines “interactive communication” as “at a minimum, a real-time synchronous, two-way audio interaction that is capable of being enhanced with video or other kinds of data transmission.”
In plain language: a phone call or video call. Texting and email do not qualify because they are not real-time synchronous. The conversation happened, but if it’s not in the chart, it didn’t happen as far as the payer is concerned.
Boosting patient engagement strategies can help ensure patients actually pick up the phone or join a video check-in each month.
6. Patient Consent
Consent must be obtained before RTM services begin. The patient needs to understand three things: that they’re agreeing to remote monitoring, what data will be collected, and that they may have cost-sharing obligations.
Verbal consent is acceptable, but it must be documented in the medical record with the date, time, and the name of the person who obtained it. Post-dated consent is an audit red flag.
7. Therapy Modifiers
When RTM is furnished by therapists, append the appropriate modifier:
- GP for physical therapists
- GO for occupational therapists
- GN for speech-language pathologists
If a physical therapist assistant (PTA) or occupational therapy assistant (OTA) provides services in whole or in part, the CQ (for PTAs) or CO (for OTAs) modifier must be appended. The de minimis standard (services must exceed 10% of the total to require the modifier) applies to codes 98975, 98979, 98980, and 98981.
Occupational therapists and SLPs follow the same RTM billing framework as PTs, just with different modifiers.
8. One Clinician Per Patient Per Period
Only one clinician can bill RTM codes for a given patient in a single 30-day period. If multiple providers in your practice treat the same patient, decide upfront who owns the RTM billing relationship.
Documentation That Survives an Audit
Audit frequency for RTM is projected to increase from roughly 8% to 12-15% annually in 2026, according to billing industry analysts. The National Law Review has warned that CMS expects increased auditing and enforcement activity related to both RPM and RTM. Preparing now is not optional.
The Five Elements Auditors Check
CMS and commercial payers conducting RTM audits look for five specific elements:
- Patient consent with date, time, and the person who obtained it
- Device identification naming the specific app or device used, with documentation of its FDA status
- Data day counts showing exactly how many days of data were transmitted during the 30-day period
- Treatment management time logs with start/stop times or specific minute counts
- Interactive communication records documenting the date, duration, and content of the real-time call
What a Defensible Monthly Note Looks Like
An auditor does not want to see a screenshot of a dashboard. As one compliance advisor put it: “They want to see a clinician who reviewed data, made decisions based on it, and documented why those decisions were appropriate.”
A strong monthly RTM note includes:
- The patient’s name and the monitoring period dates
- The device or app name and how data was transmitted
- The number of data days recorded (e.g., “18 of 30 days”)
- A summary of what the data showed and how it informed clinical decisions
- Total treatment management time with specific activities (e.g., “22 minutes: reviewed adherence data, adjusted HEP progressions, called patient to discuss form corrections”)
- The date and duration of the interactive communication
- Clinical reasoning for any plan modifications
Red Flags That Trigger Deeper Review
Practitioners on billing forums report that payers flag these patterns most frequently:
- Round-number time entries. “20 minutes” logged every month for every patient signals template-based documentation.
- Copied notes. Generic notes reused month to month are, as one billing specialist at Park Medical Billing noted, “a pattern that is easy for payers to flag during audits and nearly impossible to defend after the fact.”
- Post-dated consent. If consent is dated after the first day of monitoring, the entire episode is vulnerable.
- Missing device identification. Not naming the specific app or device in the chart creates compliance exposure.
Automating parts of this workflow, like day-count tracking and 16-day updates, reduces the chance of human error in documentation.
Common Denial Reasons and How to Avoid Them
| Denial Trigger | What Goes Wrong | How to Fix It |
|---|---|---|
| Missing time logs | No documented start/stop times for treatment management | Log time contemporaneously, not at month-end |
| No interactive communication | Text or email used instead of phone/video, or call happened but wasn’t charted | Schedule a standing monthly call and document it immediately |
| Below day threshold | Patient had only 1 day of data but 98975 was billed | Confirm minimum 2 days before submitting setup code |
| RTM/RPM confusion | RTM codes submitted for physiologic data, or both billed in same month | Train front desk and billing staff on the distinction |
| Non-FDA-compliant device | Consumer fitness tracker used for monitoring | Use only devices or apps that meet the FDA medical device definition and document the device by name |
| Billing both device supply codes | 98985 and 98977 submitted for same patient in same period | Choose one based on actual data days collected |
Practitioners in orthopedic marketing communities have raised concerns about RTM misuse, with some clinics reportedly generating codes from automated messages with no therapist involvement or clinical oversight. This kind of billing without clinical substance is exactly what CMS enforcement is targeting. Tie every code to genuine clinical value, not just revenue extraction.
Commercial Payer Considerations
Medicare’s RTM billing requirements are clearly defined. Commercial payers are a different story.
Some commercial insurers mirror Medicare’s guidelines closely. Others require additional documentation, prior authorization, or different code sets entirely. A few don’t cover RTM at all yet. The variability means you cannot assume that meeting Medicare requirements automatically satisfies your patient’s commercial plan.
That said, when commercial payers do cover RTM, the rates are often better than Medicare. Commercial PPO plans average 120-150% of Medicare rates, while HMO plans typically run 110-130%, according to clinIQ Healthcare. Verify coverage before enrolling a patient and document the payer’s specific requirements in your billing workflow.
Revenue Potential at Scale
The math is straightforward. A practice managing 100 MSK patients on full-engagement RTM (98977 + 98980) generates approximately $10,500 per month, or $126,000 per year. The new low-engagement tier (98985 + 98979) unlocks roughly $3,850 per month from 50 additional patients who previously fell below the 16-day threshold.
RTM codes remain on the CMS New Technology list through April 2030, which means they’re exempt from certain budget-neutrality adjustments. The revenue runway is long enough to justify the operational investment.
For context on how much admin time therapists already spend on non-clinical tasks, automating RTM tracking and report generation is one of the clearest time-for-revenue tradeoffs available in outpatient rehab.
How an RTM Platform Helps Meet These Requirements
Meeting RTM billing requirements manually is possible but fragile. Spreadsheets for day counts, calendar reminders for interactive communications, and copy-paste note templates all break down at scale.
A purpose-built RTM platform automates the parts that cause the most denials: tracking data days in real time, flagging when time thresholds are met, generating exportable reports with timestamps, and maintaining audit-ready records for every patient.
The platform should also meet the SaMD requirement itself, so you’re not scrambling to prove your monitoring tool qualifies as an FDA-defined medical device. Legacy printout-based HEP tools can’t meet this standard, which is why clinics still using older HEP alternatives are finding themselves locked out of RTM revenue.
Explore AC Health’s clinic plans for RTM →
A well-designed RTM workflow for clinics covers enrollment, ongoing monitoring, report generation, and claim attachment without adding hours to your staff’s week.
Frequently Asked Questions
Can physical therapists bill RTM without a physician sign-off?
Yes. RTM is the code set PTs can bill independently. No physician co-signature is required, and there’s no transfer of billing rights. The same applies to OTs and SLPs.
Can PTAs and OTAs contribute to RTM treatment management time?
Yes. PTAs and OTAs can contribute to monitoring time for codes 98980 and 98981 under general supervision. However, the de minimis standard (10%) applies, and the CQ modifier (for PTAs) or CO modifier (for OTAs) must be appended when their contribution exceeds that threshold.
Does texting or emailing a patient count as interactive communication?
No. CMS defines interactive communication as real-time, synchronous, two-way audio interaction. That means a phone call or video call at minimum. Text messages and emails are asynchronous and do not satisfy this requirement.
Can I bill both 98985 and 98977 for the same patient in the same 30-day period?
No. Device supply codes are mutually exclusive. If the patient had 2-15 days of data, bill 98985. If they had 16-30 days, bill 98977.
Can I bill RTM and RPM for the same patient in the same month?
No. CMS prohibits billing both RTM and RPM for the same patient in the same calendar month. If the patient receives both types of monitoring, you must choose one.
What happens if a patient only has 1 day of data?
You cannot bill any RTM codes. The minimum threshold for the setup code (98975) and the new low-tier device supply code (98985) is 2 days. Below that, no RTM billing is permissible.
Are RTM codes still on the New Technology list?
Yes. RTM codes remain on the CMS New Technology list through April 2030, protecting them from certain payment adjustments.
How much can a practice realistically earn from RTM?
A practice with 100 patients on full-engagement RTM (98977 + 98980) can generate approximately $10,500 per month. Adding 50 patients on the new low-engagement tier (98985 + 98979) contributes another $3,850 monthly. Commercial payer rates can push these numbers 20-50% higher.
Ready to see how your clinic can meet RTM billing requirements without adding admin hours? Schedule a free demo with AC Health →
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