TL;DR
The 2026 RTM cheat sheet covers all eight CPT codes (including three new ones), updated reimbursement rates, and the billing rules rehab clinics need to know. CMS eliminated the all-or-nothing billing cliff by adding lower-threshold tiers for both device supply and treatment management. A fully engaged RTM patient now generates roughly $135 per month in ongoing revenue, while the new low-engagement tier captures about $77 per month for patients who previously earned clinics nothing.
Three new CPT codes. Lower time and monitoring thresholds. Higher reimbursement rates. The 2026 CMS Physician Fee Schedule Final Rule made Remote Therapeutic Monitoring significantly more attractive for rehabilitation practices, and the changes took effect January 1, 2026.
This page is your 2026 RTM cheat sheet. It covers every code, every rate, every billing rule, and every pitfall that matters. Print it. Bookmark it. Share it with your billing team.
Whether you have been running RTM since 2022 or you are evaluating it for the first time, the glossary format below gives you fast answers without wading through paragraphs of preamble.
If you are looking for a platform that automates RTM tracking and reporting, explore AC Health’s pricing to see how it fits your clinic.
What Is RTM? A Quick-Start Definition
Remote Therapeutic Monitoring (RTM) is a set of CPT codes that reimburse providers for monitoring patient-reported data related to musculoskeletal and respiratory conditions between visits. CMS introduced RTM in 2022 to capture the clinical work therapists were already doing: reviewing home exercise adherence, tracking symptom changes, and adjusting treatment plans based on patient feedback.
Unlike Remote Patient Monitoring (RPM), which requires automatic data upload from a medical device, RTM permits patient self-reporting through Software as a Medical Device (SaMD) tools. This means HEP apps and patient engagement platforms qualify as the data collection “device.”
The most important distinction: RTM is the code set that PTs, OTs, and SLPs can bill independently. No physician co-signature is required. No transfer of billing rights. Your services, your revenue.
For a deeper look at how therapists actually use RTM day to day, see this RTM clinician workflow guide.
RTM vs. RPM: Know the Difference
These two programs get confused constantly. Here is what separates them:
| RTM | RPM | |
|---|---|---|
| Focus | MSK and respiratory systems, therapy adherence and response | Physiologic data (blood pressure, weight, glucose, etc.) |
| Data collection | Patient self-reporting via SaMD | Automatic upload from a medical device |
| Who bills | PTs, OTs, SLPs, physicians, qualified healthcare professionals | Physicians and clinical staff under physician supervision |
| Mutual exclusivity | Cannot bill RPM for the same patient in the same month | Cannot bill RTM for the same patient in the same month |
That last point trips people up. A single patient cannot be enrolled in both RTM and RPM during the same billing period. Pick one.
The Complete 2026 RTM Code Table
This is the centerpiece of the 2026 RTM cheat sheet. All eight codes, organized by function, with 2026 national average reimbursement rates.
Setup Code
| Code | Description | Billing Frequency | 2026 Avg. Rate | Key Restriction |
|---|---|---|---|---|
| 98975 | Initial RTM setup and patient education on use of equipment | Once per episode of care | $21.71 (Non-APM) / $21.82 (APM) | Cannot bill if fewer than 2 days of monitoring occurred |
Device Supply Codes (MSK)
| Code | Description | Billing Frequency | 2026 Avg. Rate | Key Restriction |
|---|---|---|---|---|
| 98985 🆕 | MSK device supply, 2–15 days of data transmission in a 30-day period | Per 30-day period | $51.00 | Mutually exclusive with 98977 |
| 98977 | MSK device supply, 16–30 days of data transmission in a 30-day period | Per 30-day period | $51.44 | Mutually exclusive with 98985 |
Device Supply Codes (Respiratory)
| Code | Description | Billing Frequency | 2026 Avg. Rate | Key Restriction |
|---|---|---|---|---|
| 98984 🆕 | Respiratory device supply, 2–15 days in a 30-day period | Per 30-day period | $52.00 | Mutually exclusive with 98976 |
| 98976 | Respiratory device supply, 16–30 days in a 30-day period | Per 30-day period | See CMS PFS Lookup | Mutually exclusive with 98984 |
Treatment Management Codes
| Code | Description | Billing Frequency | 2026 Avg. Rate | Key Restriction |
|---|---|---|---|---|
| 98979 🆕 | Treatment management, first 10–19 minutes | Per calendar month | $26.00 | Mutually exclusive with 98980; requires interactive communication |
| 98980 | Treatment management, first 20+ minutes | Per calendar month | $54.00 | Mutually exclusive with 98979; requires interactive communication |
| 98981 | Treatment management, each additional 20 minutes | Per calendar month | $41.42 (Non-APM) / $41.63 (APM) | Add-on to 98980 only; can be billed unlimited times per month |
A note on the 98977 rate: after the CMS final rule, many expected that code to decrease to roughly $38.75. Instead, practice expense (PE) adjustments pushed it to $51.44, coming in 32.75% higher than expected.
New for 2026: Three Codes That Changed Everything
The three codes marked 🆕 above deserve their own section because they fundamentally changed RTM economics.
CPT 98985: The Low-Threshold MSK Device Code
Before 2026, a patient needed 16 or more days of data transmission in a 30-day period for a clinic to bill any device supply code. If a patient logged 14 days and then went on vacation, the clinic got nothing. CPT 98985 creates a reimbursable tier for 2 to 15 days of MSK data transmission, paying $51.00 per 30-day period.
CPT 98984: The Low-Threshold Respiratory Device Code
The respiratory counterpart to 98985. Same concept, same threshold: 2 to 15 days of data transmission. National average rate of $52.00.
CPT 98979: The 10-Minute Treatment Management Code
This one is arguably the biggest deal. Prior to 2026, treatment management required a minimum of 20 minutes of provider time per month (billed under 98980). Spend 18 minutes managing a patient’s program? That yielded $0. As Kathryn Rigda, PT, described in a Raintree/Limber Health webinar, RTM had been constrained by an “all-or-nothing” payment structure that did not reflect how patients or clinics actually operate. CPT 98979 fixes this by creating a billable tier for 10 to 19 minutes of monthly treatment management at $26.00.
The combined effect: the all-or-nothing cliff is gone. If a patient participates imperfectly but your team is still monitoring and supporting them, you no longer have to choose between forcing compliance or absorbing unreimbursed work. CMS estimates these new codes could increase billable RTM patients by 20–40%.
Billing Rules Glossary
This section defines every billing rule and term you will encounter when working with the 2026 RTM codes. Each entry is written for billing staff who need precision, not fluff.
Mutual Exclusivity
You cannot bill both tiers of the same code category in the same period. Specifically:
- 98985 (2–15 days) and 98977 (16–30 days) are mutually exclusive
- 98984 (2–15 days) and 98976 (16–30 days) are mutually exclusive
- 98979 (10–19 min) and 98980 (20+ min) are mutually exclusive
You also cannot add 98981 (the additional 20-minute add-on) to a 98979 base code. The add-on only works with 98980.
Interactive Communication
Treatment management codes (98979, 98980, 98981) require at least one live, interactive communication with the patient or caregiver during the calendar month. Text messages, chat, and email do not qualify.
A significant 2026 clarification: CMS language now suggests that an in-person conversation about RTM during a standard clinic visit may satisfy this requirement, provided it is documented in the EMR. However, legal analysis from the Nixon Law Group warns that both CMS and the CPT Manual have explicitly prohibited in-clinic discussion time from counting toward RPM or RTM time requirements. This remains a gray area. The conservative approach: document any in-person RTM discussion separately and clearly, but do not rely solely on it to meet the interactive communication standard.
For practical strategies on staying connected with patients between visits, these patient engagement tips are worth reviewing.
Sometimes Therapy Designation
Starting January 1, 2026, all RTM codes (including the new 98985 and 98979) carry a “sometimes therapy” designation. This means that when a therapist furnishes the service, therapy-specific billing rules apply, including modifier requirements and therapy cap tracking.
Therapy Modifiers (GP / GO / GN)
When a therapist provides RTM services, the correct modifier must be appended to the claim:
- GP — Physical therapist
- GO — Occupational therapist
- GN — Speech-language pathologist
Missing these modifiers is one of the most common denial triggers. If you are an OT billing RTM, learn more about the platform options built for occupational therapists.
De Minimis Standard (10% Rule)
The de minimis standard applies to codes 98975, 98979, 98980, and 98981 when services are provided in whole or in part by a Physical Therapist Assistant (PTA) or Occupational Therapy Assistant (OTA). When the standard applies, the CQ modifier (for PTAs) or CO modifier (for OTAs) must be appended. Importantly, the de minimis standard does not apply to device supply codes 98985 and 98977.
30-Day Period vs. Calendar Month
This distinction catches people off guard. Device supply codes (98985, 98977, 98984, 98976) are billed based on a rolling 30-day period starting from when monitoring begins. Treatment management codes (98979, 98980, 98981) are billed at the end of each calendar month. It is entirely possible to bill a treatment management code in a calendar month while the 30-day device supply window has not yet closed or met its threshold.
For a complete breakdown of RTM billing mechanics, see this RTM billing requirements checklist.
Episode of Care
In the RTM context, an episode of care begins when RTM services start and ends when established treatment goals are met. The setup code 98975 is billed once per episode, not once per month. If a patient’s goals are met and a new episode begins later, 98975 can be billed again.
SaMD (Software as a Medical Device)
RTM does not require a physical device strapped to a patient. The software itself can be the device. This is why HEP apps, patient engagement platforms, and similar tools qualify as the RTM data collection mechanism. The software collects patient self-reported data (exercise completion, symptom responses, functional scores) and transmits it for provider review.
2026 Conversion Factor
The non-qualifying APM conversion factor for 2026 is $33.40, up from $32.35 in 2025, a 3.26% increase. The APM conversion factor is $33.57.
KX Modifier Threshold
The 2026 therapy cap threshold is $2,480 for combined physical therapy and speech-language pathology services, and $2,480 for occupational therapy services. RTM services billed under a therapy plan of care count toward this threshold. Append the KX modifier when claiming services above the cap to indicate medical necessity.
New Technology List
All RTM codes remain on the CMS New Technology List, which means they will stay in effect until at least April 2030, when CMS will review available data to determine whether changes are needed.
Code Stacking
You can stack RTM with other remote care programs like Chronic Care Management (CCM), Behavioral Health Integration (BHI), and Advanced Primary Care Management (APCM) for the same patient. The one exception: RTM and RPM are mutually exclusive for the same patient in the same month.
Eligible Providers
As of 2026, RTM can be billed by physicians, physical therapists, occupational therapists, speech-language pathologists, and mental health providers. PTs, OTs, and SLPs can bill independently without physician co-signatures.
Common Mistakes and Denial Triggers
The most frequent RTM billing errors, compiled from practitioner reports and billing analyses:
- Billing 98985 and 98977 in the same 30-day period for the same patient. They are mutually exclusive.
- Billing 98979 and 98980 in the same calendar month. Also mutually exclusive.
- Missing GP, GO, or GN modifiers when a therapist provides the service.
- No documented, active therapy plan of care on file. RTM must be tied to skilled therapy.
- Post-dated RTM notes. The interactive communication required for treatment management codes must be documented at the time it occurs. Post-dated notes are a consistent audit trigger.
- Using outdated codes or rates from 2025 or earlier.
- Counting text messages or emails as interactive communication. They do not qualify.
Practitioners on Reddit repeatedly point to workflow friction, patient buy-in, and staff bandwidth as the real barriers to RTM success. The code knowledge usually is not the problem. Operationalizing RTM within existing clinic schedules is.
To reduce the administrative burden, many clinics turn to automated RTM reporting tools that handle the tracking so clinicians can focus on patient care.
Revenue Cheat Sheet
Here is what RTM actually pays, broken down by patient engagement level.
Per-Patient Monthly Revenue
| Scenario | Codes Billed | Monthly Revenue |
|---|---|---|
| Full engagement (ongoing) | 98977 ($51.44) + 98980 ($54) + 98981 ($41.42) | ~$147/month |
| Full engagement (first month) | Add 98975 ($21.71) | ~$169 first month |
| Low engagement | 98985 ($51) + 98979 ($26) | ~$77/month |
Revenue at Scale
| Patient Volume | Engagement Level | Monthly Revenue | Annual Revenue |
|---|---|---|---|
| 100 patients | Full (98977 + 98980) | ~$10,500 | ~$126,000 |
| 50 patients | Low (98985 + 98979) | ~$3,850 | ~$46,200 |
| 150 patients blended | Mix of both | ~$14,350 | ~$172,200 |
Those 50 low-engagement patients are the ones who previously fell below the billing threshold. They generated zero RTM revenue before 2026. Now they represent nearly $46,000 per year in recovered income for work clinicians were already doing.
Only about 30% of patients actually complete their home exercise programs consistently. That statistic is exactly why the low-engagement tier matters. Real patients forget, travel, and struggle with technology. The new codes meet them where they are.
RTM Workflow Checklist
The code knowledge is the easy part. The hard part is building a repeatable process. Here is the six-step workflow:
- Enroll — Identify eligible patients with active therapy plans of care. Set up RTM (bill 98975).
- Educate — Teach the patient how to use the SaMD tool (app, platform) for self-reporting.
- Monitor — Track incoming data for at least 2 days (minimum for any billing) through 30 days.
- Communicate — Conduct at least one live, interactive communication per calendar month. Document it immediately.
- Document — Record all RTM activities, time spent, and clinical decisions in the EMR. No post-dating.
- Bill — Apply correct codes, modifiers, and tier based on days of monitoring and minutes of management.
For a detailed walkthrough of this process, including automation options, see the full RTM workflow for clinics.
FAQ
Can I bill 98985 and 98977 in the same 30-day period?
No. These codes are mutually exclusive. If a patient transmits data for 16 or more days in a 30-day period, bill 98977. If they transmit for 2 to 15 days, bill 98985. Never both.
Does texting count as interactive communication for treatment management codes?
No. CMS requires a live, interactive communication. Text messages, chat, and emails do not qualify. Phone calls, video calls, and documented in-person conversations are the accepted formats.
Do in-person conversations about RTM satisfy the interactive communication requirement?
This is a gray area. CMS language in the 2026 final rule suggests it may count if documented in the EMR. However, legal analysis from Nixon Law Group notes that both CMS and the CPT Manual have explicitly prohibited in-clinic discussion time from being attributed to RTM time requirements. Be conservative: document in-person RTM discussions separately, but consider supplementing with a phone or video check-in.
Can PTs bill RTM without a physician co-signature?
Yes. RTM is the code set PTs can bill independently. The same applies to OTs and SLPs. No physician co-signature or transfer of billing rights is required.
Are RTM codes permanent?
They are on the CMS New Technology List, which keeps them in effect until April 2030. At that point, CMS will review the data and decide whether to make changes. They are not going away soon.
Does RTM count toward the therapy cap?
Yes. When RTM services are billed under a therapy plan of care with therapy modifiers (GP, GO, GN), they count toward the $2,480 KX modifier threshold.
Can I stack RTM with CCM or other remote care programs?
Yes. You can bill RTM alongside CCM, BHI, and APCM for the same patient. The only restriction is that RTM and RPM cannot be billed for the same patient in the same calendar month.
Can 98981 be added to a 98979 base code?
No. The add-on code 98981 (each additional 20 minutes) can only be appended to 98980 (first 20+ minutes). It cannot be stacked on top of the lower-tier 98979 code.
This 2026 RTM cheat sheet covers every code, rate, and rule your billing team needs. If you are ready to implement RTM with automated tracking and one-click reporting, contact AC Health to schedule a demo and see the platform in action.
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